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1.   INTRODUCTION

 

The Findon Hall Management Committee is committed to protecting any personal data shared with us by individuals or organisations, and keeping it safe.

 

This Privacy Notice provides you with details of how we collect and process the personal data received from you, from other organisations and through your use of our website www.culbokie.info.

 

By providing us with your data, you warrant to us that you are over 13 years of age.

 

The Findon Hall Management Committee is the Data Controller and we are responsible for your personal data (referred to as “The Findon Hall”, “we”, “us” or “our” in this privacy notice).

 

Contact Details

 

Our full details are:

 

Full name of legal entity: Findon Hall Management Committee.

 

Email address: findon.hall@culbokie.info

 

Postal address: Eisir, Balmeanach, Culbokie, IV7 8JH.

 

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at findon.hall@culbokie.info.

 

  1. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

 

Personal data means any information capable of identifying an individual. It does not include anonymised data.

 

We may process the following categories of personal data about you:

 

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through letter, e-mail, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests, which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

 

  • Customer Data that includes data relating to hiring of the hall, such as your name, title, billing address, email address, phone number and booking form. In some cases the booking form also requires the names and signatures of four stewards/parents. The stewards/parents also have to provide their names and sign the form. We process this data to manage your hall booking and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract. We collect data when you attend committee meetings, EGM and AGMs and note your name on publicly available minutes of these meetings. We process this data for record keeping. Our lawful ground for this processing is our legitimate interests, which in this case is to manage the governance of the organisation.

 

  • Fundraising Data that incudes data relating to running our annual 100 Club draw and other fundraisers that require we process your data, such as your name, postal address, email address, phone number and declaration form. We process this data to administer the fundraiser, advise you of any wins you have, advise the local community who has won and to deliver relevant fundraising opportunities to our supporters. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer and grow our business and to decide our fundraising and marketing strategy.

 

  • Marketing Data that includes data about your preferences in receiving marketing from us and your communication preferences. We process this data to enable you to partake in our promotions such as fundraisers, competitions, prize draws and free give-aways, to deliver relevant website, newsletter and social media content to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to develop and grow our business and to decide our fundraising and marketing strategy.

 

  • Volunteer Data that includes data relating to the governance of the organisation such as committee member/Trustee name, e-mail address, postal address, telephone number. We process this information to administer the organisation through activities such as: recording your attendance at meetings in publically available minutes, to record your name in annual accounts, contact you about meetings and informal committee activities such as hall maintenance. We may need to collect further information from you such as your eligibility to serve as a Trustee, sample signature, photo identification and bank account details and other means as requested to verify your identity.

 

We may use Customer Data, Fundraising Data and Marketing Data to deliver relevant website, social media, newsletter content and advertisements to you. Our lawful ground for this processing is legitimate interests, which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

 

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to hire the hall to you or to get a prize to you). If you don’t provide us with the requested data, we may have to cancel your hall hire but if we do, we will notify you at the time.

 

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

 

We may process your personal data without your knowledge or consent where this is required or permitted by law.

 

3. HOW WE COLLECT YOUR PERSONAL DATA

 

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this https://www.culbokie.info/cookie-policy

 

We may receive data from analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.

 

  1. MARKETING COMMUNICATIONS

 

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

 

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you have hired the hall previously or asked for information from us about hall hire or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

 

The Findon Hall will not share your data with third parties for marketing purposes.

 

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at findon.hall@culbokie.info at any time.

 

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions.

 

5. DISCLOSURES OF YOUR PERSONAL DATA

 

We may have to share your personal data with the parties set out below:

 

  • Service providers who provide IT and system administration services.

 

  • Professional advisers including lawyers, bankers, auditors and insurers.

 

  • Government or public bodies that require us to report processing activities.

 

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

 

6. INTERNATIONAL TRANSFERS

 

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data; so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

 

If any of our third parties service providers are based outside the EEA their processing of your personal data will involve a transfer of data outside the EEA.

 

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

 

  • We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or

 

  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

 

  • If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

 

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

 

7. DATA SECURITY

 

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those Trustees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

 

8. DATA RETENTION

 

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

 

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

 

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

9. YOUR LEGAL RIGHTS

 

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

 

You can see more about these rights at:

 

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

 

If you wish to exercise any of the rights set out above, please email us at indon.hall@culbokie.info

 

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 or refuse to comply with your request in these circumstances.

 

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.

 

We try to respond to all legitimate requests within one month. Occasionally it may 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.

 

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

 

10. 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 notice of every website you visit.

 

11. COOKIES

 

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 this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.culbokie.info/cookie-policy

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