Privacy Policy

[vc_row][vc_column][vc_column_text]This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally identifiable information’ (PII) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.

What personal information do we collect from the people that visit our blog, website or app?

When using our site, as appropriate, you may be asked to enter your name, email address or other details to help you with your experience.

How do we use your information?

We may use the information we collect from you when you register, make a purchase, sign up for our newsletter, unlock the content, respond to a survey or marketing communication, surf the website, or use certain other site features in the following ways:

  • To personalize user’s experience and to allow us to deliver the type of content and product offerings in which you are most interested
  • To improve our website in order to better serve you.
  • To allow us to better service you in responding to your customer service requests.
  • To administer a contest, promotion, survey or other site feature.
  • To send periodic emails regarding your order or other products and services.

Do we use ‘cookies’?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

  • Understand and save user’s preferences for future visits.
  • Memorize the users who have unlocked access to premium content.

If you disable cookies off, some features will be disabled. It will affect the users experience and some of our services will not function properly.

Third Party Disclosure

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

Third party links

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

If there are any questions regarding this privacy policy you may contact us.

1. Data protection principles
CheltenhamTalk.co.uk is committed to processing data in accordance with its responsibilities under the GDPR.

Article 5 of the GDPR requires that personal data shall be:

a.       processed lawfully, fairly and in a transparent manner in relation to individuals;

b.      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;

c.       adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

d.      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;

e.       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

f.       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.”

2. General provisions
a.       This policy applies to all personal data processed by CheltenhamTalk.co.uk.

b.      The Responsible Person shall take responsibility for CheltenhamTalk.co.uk’s ongoing compliance with this policy.

c.       This policy shall be reviewed at least annually.

d.      CheltenhamTalk.co.uk shall register with the Information Commissioner’s Office as an organisation that processes personal data.

3. Lawful, fair and transparent processing
a.       To ensure its processing of data is lawful, fair and transparent, CheltenhamTalk.co.uk shall maintain a Register of Systems.

b.      The Register of Systems shall be reviewed at least annually.

c.       Individuals have the right to access their personal data and any such requests made to CheltenhamTalk.co.uk shall be dealt with in a timely manner.

4. Lawful purposes
a.       All data processed by CheltenhamTalk.co.uk 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).

b.      CheltenhamTalk.co.uk shall note the appropriate lawful basis in the Register of Systems.

c.       Where consent is relied upon as a lawful basis for processing data, evidence of opt-in  consent shall be kept with the personal data.

d.      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 CheltenhamTalk.co.uk’s systems.

5. Data minimisation
a.       CheltenhamTalk.co.uk shall ensure that personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

b.      [Add considerations relevant to CheltenhamTalk.co.uk’s particular systems]

6. Accuracy
a.       CheltenhamTalk.co.uk shall take reasonable steps to ensure personal data is accurate.

b.      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.

c.       [Add considerations relevant to CheltenhamTalk.co.uk’s particular systems]

7. Archiving / removal
a.       To ensure that personal data is kept for no longer than necessary, CheltenhamTalk.co.uk shall put in place an archiving policy for each area in which personal data is processed and review this process annually.

b.      The archiving policy shall consider what data should/must be retained, for how long, and why.

8. Security
a.       CheltenhamTalk.co.uk shall ensure that personal data is stored securely using modern software that is kept-up-to-date.

b.      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.

c.       When personal data is deleted this should be done safely such that the data is irrecoverable.

d.      Appropriate back-up and disaster recovery solutions shall be in place.

9. Breach
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, CheltenhamTalk.co.uk 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).

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