Pied A Terre Adventures Ltd (PATA) is committed to protecting your personal information and to being transparent about the information we hold about you, as well as giving you control on how we use it. Using personal information allows us to develop a better understanding of our customers, and in turn provides you with relevant and timely information about the work that we do.
The purpose of this policy is to give you a clear explanation about how we collect and process your personal information, including any data you may provide through our website, when you sign up to our newsletters, and book any of our activities.
1. The Data Protection Act (1998 )
2. The Privacy and Electronic Communications (EC Directive) Regulations (2003)
3. The EU General Data Protection Regulation (Regulation EU 2016/679), (‘GDPR’), effective from 25 May 2018
This policy explains:
1. What information we may collect about you
2. How we may use that information
3. In what situations we may disclose your details to third parties
4. Information about how we keep your personal information secure, how long we maintain it for and your rights to be able to access it
If you have any questions, at any time, about this policy or the personal information we hold about you, or wish to change how you would like to hear from us, please contact us: By email: firstname.lastname@example.org
By post: Data Controller, Pied A Terre Adventures Ltd, Summit House, 12 Morris Drive, Billingshurst, West Sussex, UK, RH14 9SF
By phone: 01403 788994
WHO WE ARE
PATA is a West Sussex based company, providing walking based activities for individuals, groups, corporate clients and charities. The company is incorporated in England and Wales (number 7409635).
INFORMATION WE MAY COLLECT ABOUT YOU
Personal information means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:
1. Information you give us.
1.1. When you register on our website, book an activity, by phone or online via our website, by signing up for one of our other events or workshops, by updating your preferences on our website or by purchasing a gift voucher, we will store personal information you give us such as your name, email address, postal address, billing address and telephone number. We will also store a record of your purchases.
2. Information about your interactions with us.
2.1. When you visit our website, we collect information about how you interact with our content. When we send you a mailing we store a record of this and in the case of emails, we keep a record of which ones you have opened and which links you have clicked on.
3. Information about marketing & communications preferences.
3.1. This includes your preferences in receiving marketing from us and our third parties and your communication preferences. This helps us to manage our relationship with you and ensures you only receive communications from us that are relevant and timely.
4. Sensitive personal data.
4.1. Data Protection law recognises that certain categories of personal information are more sensitive, such as health information, race, religious beliefs and political opinions. The only information of this type which we will ask you for are relevant health/ medical details. This is to ensure your safety and well-being during any of our activities, courses, or events.
5.1. From time to time photographs are taken on PATA activities and these may appear in PATA brochures, promotional material our website and social media. We will never use names with the photos without your explicit consent. Occasionally photos may be shared with relevant third parties e.g. to specific charities in relation to a charity event arranged on their behalf. If you do not wish for your image to be used you must inform Pied A Terre Adventures in writing.
6. Information from third parties.
6.1. We occasionally receive information about you from third parties as set out below:
6.1.1. Analytics providers such as Google
6.1.2. Advertising networks such as Facebook
6.1.3. Search information providers such as Google AdWords
LEGAL BASIS There are three bases under which we may process your data:
1. Contract purposes.
1.1. When you make a purchase from us, you are entering into a contract with PATA. In order to perform this contract we need to process and store your data. For example, we may need to contact you by email or telephone to provide you with essential activity information, in the case of the cancellation, or in case of problems with your payment.
2. Legitimate business interests.
2.1. In certain situations, we collect and process your personal data for purposes that are in our legitimate organisational interests. However we only do this if there is no overriding
prejudice to you by using your personal information in this way. We describe below all situations where we may use this basis for processing.
3. With your explicit consent.
3.1. For any situations where the first two bases above are not appropriate, we will instead ask for your explicit consent before using personal information in that specific situation.
4. If you fail to provide personal information.
4.1. Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with an activity). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
5. Users under 18.
5.1. We understand that people aged under 18 may use our website. If you are under 18, please ensure that you obtain your parent/guardian’s consent before hand whenever you provide personal information to us. To request to see our Safeguarding Policy, please contact us, using the contact details at the end of this policy.
HOW WE MAY USE YOUR INFORMATION
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the contract we are about to enter into or have entered into with you.
2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
3. Where we need to comply with a legal or regulatory obligation.
4. Where we have your explicit consent before using your personal information in that specific situation. However, generally we do not rely on consent as a legal basis for processing your personal information and you have the right to withdraw consent to marketing at any time by contacting us. You will find the relevant contact details at the end of this policy.
5. Marketing communication
5.1. We aim to communicate with you about the work that we do in ways that you find relevant, timely, respectful and never excessive. To do this, we use data that we have stored about you, such as which activities you have booked for in the past, as well as any contact preferences you may have told us about.
5.2. We use our legitimate organisational interest as the legal basis for communications by post and email. In the case of postal mailings, you may opt-out of receiving these at any time using the contact details at the end of this policy or by updating your contact preferences.
5.3. We use MailChimp a third-party provider to manage and send our email marketing campaigns. MailChimp also provides us with statistics including numbers of clicks and opens – these help us review and improve our email marketing.
5.4. We keep a record of when and how you consented to joining our email marketing list, as well as a list of those who have asked to no longer by contacted.
5.5. You can unsubscribe from our marketing emails at any time by clicking the unsubscribe link at the bottom of an email, or by contacting our data protection officer at email@example.com
5.6. In the case of email, we will give you an opportunity to opt into receiving electronic communications during your first purchase with us. If you do opt-in to receiving emails from
us, we will then provide you with the option to unsubscribe in every email that we send you subsequently.
5.7. As part of our service to you, we may contact you by email or telephone to provide essential information related to your purchase or activity.
6. Other processing activities
6.1. In addition to marketing and news communications, we also process personal information in the following ways that are within our legitimate organisational interests.
6.2. We may analyse data we hold about you to ensure that the content and timing of communications that we send you are as relevant to you as possible.
6.3. We may analyse data that we hold about you in order to identify and prevent fraud.
6.4. In order to improve our website, we may analyse information about how you use it and the content that you interact with.
In all the above cases we will always keep your rights and interests at the forefront to ensure that they are not overridden by your own interests or fundamental rights and freedoms. You have the right to object to any of this processing at any time. If you wish to do this, please use the contact details at the end of this policy. Please bear in mind that if you do object, this may affect our ability to carry out tasks above that are for your benefit.
DISCLOSURE OF YOUR DETAILS TO THIRD PARTIES
There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:
1. To our service providers who process data on our behalf and on our instructions (for example our booking platform, email distribution service and mailing houses). We require all third parties to respect the privacy of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
2. Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).
3. To fulfil our service we will share limited data with the named charities, accommodations and service providers that are used specific only to and during the course of your activity, course, holiday or event. Any further subscription and communication between you and the charity or provider would be then subject to the same expressed consent and permission you give them directly.
4. We do not sell personal details to third parties for any purpose.
SECURITY OF YOUR PERSONAL INFORMATION
2. Payment details
2.1. When you provide payment details these are not stored by PATA is any way (either on paper or digitally), but are securely delivered directly to our payment processor (Stripe) who fully encrypt and secure the data.
3. Security of your personal information
3.1. We have put in place appropriate safeguards (both in terms of our procedures and the technology we use) to keep your personal information as secure as possible. We will ensure that any third parties we use for processing your personal information do the same and that they will only process your personal information on our instructions. The third parties will also be subject to a duty of confidentiality.
4. We will not transfer, process or store your data anywhere that is outside of the European Economic Area, unless we have a contractual agreement in place that is of an equivalent standard to GDPR.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
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 requirements.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal information, as follows:
1. Request access to your personal information
1.1. You have a right to request a copy of the personal information that we hold about you. Please use the contact details at the end of this policy if you would like to exercise this right or any of the rights listed below. If you are a European citizen and consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, i.e. the Information Commissioner’s Office.
2. Request correction of your personal information
2.1. You have the right to request that we correct the personal information we hold about you, although we may need to verify the accuracy of the new information you provide to us.
3. Request erasure of your personal information
3.1. You have the right to request that we delete or remove personal information where there is no good reason for us continuing to process it. Please note that we may not always be able to comply with your request for erasure if there are specific legal reasons which will be notified to you at the time of your request.
4. Object to processing of your personal information
4.1. You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
5. Request restriction of processing your personal information
5.1. You have the right to request that we suspend the processing of your personal data in the following scenarios:
5.1.1. if you want us to establish the data’s accuracy
5.1.2. where our use of the data is unlawful but you do not want us to erase it
5.1.3. 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
5.1.4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Request transfer of your personal information
6.1. You have the right to request that the personal information we hold about you is transferred to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Please 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.
7. Right to withdraw consent
7.1. In circumstances where we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. 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.
8. No fee usually required
8.1. You will not have to pay a fee to access your personal information (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 may refuse to comply with your request in these circumstances.
9. What we may need from you
9.1. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.
10. Time limit to respond
10.1. 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 and keep you updated.
We go to great lengths to ensure your data is extremely secure and handled with the utmost care. However, should a data breach occur, we will contact you by email within 72 hours to notify you that
this has happened. We will follow up shortly after with a more complete explanation of the breach, how it happened, what data was breached, the steps taken to remedy the breach and what you need to do next.
CONTACT DETAILS AND FURTHER INFORMATION
Please also contact us if you have any questions about the information we hold about you, or to change your contact preferences with us: Email us: firstname.lastname@example.org
Call us: 01403 788994
Write to us:
Data Controller, Pied A Terre Adventures Ltd, Summit House, 12 Morris Drive, Billingshurst, West Sussex, UK, RH14 9SF