PRIVACY POLICY

Please find below our GDPR Privacy Policy which explains about your personal data. This is incorporated into our terms of dealing with you, it is necessary for our dealings with you and does not require any additional consent. If however you are not happy with our policy, you do have the choice of not dealing with us. If you wish to deal with us but have an objection to any part of our policy, please contact us to discuss it.

COMMUNITY PERKS LTD

Privacy Notice General Data Protection Regulation (GDPR)

What

This privacy notices covers Community Perks Ltd (CPL). We are committed to protecting your personal information. In this notice, references to ‘we’, ‘us’ or ‘our’ mean CPL. This notice explains how we collect and use the personal information about you.

Who

We are Community Perks Ltd (CPL), a company providing a perks based membership scheme. CPL is a data controller under data protection legislation and all contact details are shown at the end of this notice. We act in our administration through our limited company and, as relevant, our directors, employees and agents.

Information

We gather and collect your information via the following means: in person, on paper/in writing, by phone and text, electronically including by email, electronic applications including third party web-based applications and internet portals which you may enter your data into.

Your data is stored securely as follows: in paper files, on electronic files, on our data-bases, on third party data bases and any applications which you may enter your data into.

We collect, store, process and disclose data as follows which varies depending on the type of customer you are:

 

Client type

 

What Data is Collected, Stored and Processed

 

How Data Is Disclosed
(only where necessary and proportionate)

 

Members

 

Your name and email address. Any additional data collected from time to time, e.g. if you make an enquiry with us and provide additional data such as your address.

  • Where required for the performance of the contract.
  • We will not disclose your data to other members unless you authorise us to do so.
  • We will not disclose your data to schools or recipients of your donation unless you authorise us to do so.
  • We will not disclose your data to vendors unless either you authorise us to do so or it is necessary to do so, e.g. where you have a enquiry.
  • Where we are investigating any alleged or potential abuse of the scheme we may disclose your data to enable us to complete that investigation.
  • Where required by law.
  • Where you make a review or leave comments or feedback on any publicly accessible forum, we may disclose proportionate personal information in replying to such review/comments.
  • Where you abuse the scheme or your membership terms, we may disclose your data to protect others.
 

Schools/Charities

 

Your organisational name, address, telephone numbers and email address, and individually named contacts.

  • Where required for the performance of the contract, in particular to make members aware that they can make a donation to you.
  • Where required by law.
  • Where you make a review or leave comments or feedback on any publicly accessible forum, we may disclose proportionate personal information in replying to such review/comments.
 

Vendors/Suppliers

 

Your organisational name, address, telephone numbers and email address, and individually named contacts.

  • Where required for the performance of the contract, in particular to make members and potential members aware that you are a supplier (we will not disclose data that is commercially or privately semsitive).
  • Where required by law.
  • Where you make a review or leave comments or feedback on any publicly accessible forum, we may disclose proportionate personal information in replying to such review/comments.

Using your Data

We will use your data, in addition to that which is mentioned above, to maintain relevant contact, including, but not limited to: sending you information about products or services that you have enquired about; to products and services, to maintain the accuracy of your information and communicate with you for any other reasons related to your requirements, share with other regulatory authorities and any other party when sharing of information is required by law.

Payment Card Data

Where you submit payment card data details to us these will only ever be stored on electronic basis which meet the Payment Card Industry Data Security Standard (PCI DSS).

Disclosure of data to third parties for marketing

We will not disclose any of your personal data to any third parties for the purposes of marketing, except where you have expressly given permission for us to do so, or you have requested or expressed an interest in services performed by those third parties, and in such cases we will disclose your contact data and proportionate and appropriate details to allow for the providing or assessing of such services.

The legal basis of processing your data

The legal bases of processing your data are: ‘contract’, as defined by Article 6 of the General Data Protection Regulations where processing is necessary for the performance of a contract to which the data subject is party. ‘legal obligation’, where processing is necessary for compliance with a legal obligation for example compliance with anti-money laundering legislation and accounting practices. ‘legitimate interest’, where processing is required for maintaining contacts with customers and to enable conflict of interest checks or to hold data to the other parties to contracts with a client (such as residential tenants).

Who will have access to the information

We share your information within CPL. We may also share your information with limited third parties (as detailed above) and data processors who may need to access your information for performing the purposes specified above. We may sometimes outsource some of the services set out above to reputable third parties, including for the purpose of holding, processing and ensuring the security of your data. We have data protection compliant agreements in place with all such service providers, so they would only use your information according to our instructions. We take reasonable organisational and technical measures to protect your information against unauthorised access, modification or misuse. We use services provided by reputable and expert security providers and your information is accessed by employees, agents and third party partners on a needs-only basis.

How long will we keep your information

In the absence of any legal requirements, your personal data will be retained for as long as necessary for the purpose of processing as listed above. This means your data will be deleted if you withdraw consent (and we agree) to processing or the data is no longer required or inaccurate. If you decide to cancel any services, we will hold your information for a period which is deemed reasonable. As a general rule, we may keep your data for six years in line with tax requirements, or up to ten years in line with other statutory requirements. We may, on occasion, keep data for longer if there is a genuine necessity to do so. Where you request, and we agree to delete your data, you agree to absolving us of any liability whatsoever for any claim or complaint that you either have made or may make in the future, and further in requesting that we delete your data, you are stating that you have no complaint or claim whatsoever on CPL, their directors, employees, agents or any persons or entities associated with the company whatsoever. This is an absolute condition as it will be impossible for us to resolve any compliant after we have deleted your data. If you stop having any dealings with us, this still applies.

How to keep us updated with any changes to your information

Please remember to keep us updated on the personal data we hold on you if it is inaccurate or incomplete. All requests to update your personal data must be sent in writing to CPL and third parties will be informed, where possible. Failing to keep us updated with your personal data and contact details may lead to removal of your requirements from our database and you missing out on products or services.

Your rights

You have the right to: 1) To keep us updated. 2) Request a copy of the personal information we hold about you. We require you to prove your identity with two pieces of approved identification. Please submit your request in writing to contact details shown at the end of this notice. We will respond as soon as possible but no later than on month of receipt of your written request and confirmed ID. Please provide as much information as possible about the nature of your contact with us to help us locate your records. This request is free of charge unless the request is repetitive, unfounded or excessive and in such cases we may reject your request or make a reasonable charge. 3) Have any inaccuracies in your data corrected. If you would like to update the details we hold about you, please contact us on the details set out at the end of this notice. 4) Request that we delete your personal data so it is erased from our records. 5) Object to certain types of processing such as direct marketing. 6) Object to automated processing, including profiling.

Enquiries and Complaints

Please contact us if you have any enquiries arising from this privacy notice. Where possible, please raise all enquires in writing. If you are unhappy with our work or something that we have done or failed to do, please inform us in writing. We will acknowledge receipt of all complaints and will endeavour to investigate the complaint as soon as reasonably practicable. All complaints should be sent to:

The Operations Director, Community Perks Ltd, 115 Cregagh Road, Belfast, BT6 0LA: mark@communityperks.co.uk

You may also complain directly to the Information Commissioner’s Office if you are concerned with how we are handling your personal information. Their contact details are shown below:

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Tel: 0303 123 1113 or 01625 545745 Website: www.ico.gov.uk

Review of CPL Privacy Notice

This Notice was last reviewed in October 2019. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address you have provided to us.