Active Beginnings respects your privacy and is committed to protecting your personal data. This privacy notice outlines the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and will also tell you about your privacy rights and how the law protects you. Active Beginnings provides business to business marketing and advertising services and does not provide services direct to consumers. The personal data which Active Beginnings collects about you, or receives from you, will be in your capacity as an authorised representative of the relevant business which Active Beginnings is in discussions with and/or has entered into a contract with, in respect of the provision of products and/or services.
- Who we are
Active Beginnings is the data controller and is responsible for your personal data (collectively referred to as “Active Beginnings ”, “we”, “us” or “our” in this privacy notice).
We have appointed a data protection compliance manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection compliance manager using the details set out below.
Full name of legal entity: Active Beginnings
Name or title of data protection compliance manager: Tim Affleck
Email address: firstname.lastname@example.org
Changes to the privacy notice and your duty to inform us of changes
We may change this privacy notice from time to time. Any changes we make to this privacy notice in the future will be posted on our website and, where appropriate, notified to you by email. This version was last updated on 21st May 2018.
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.
The data that we collection about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you depending on the nature of products and/or services we are providing and what we are contracted to do for the business on whose behalf you are acting. We have grouped together the types of personal data as follows:
- Identity Data includes first name, last name, username or similar identifier and title.
- Contact Data includes email address, telephone numbers and postal address.
- Technical Data 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 and other technology on the devices you use to access our website.
- Usage Data includes information about how you use our website and our products and/or services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
The products and/or services which we provide together with our website are not intended for children and we do not knowingly collect any data relating to children.
If you fail to provide personal details
Where we need to collect personal data by law, or under the terms of a contract we have with your business and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with your business. In this case, we may have to cancel such products and/or services but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms on our website or by corresponding with us by post, phone, email, social media or otherwise on behalf of your business. This includes personal data you provide when you:
- make an enquiry about our products and/or services;
- subscribe to our publications;
- request marketing to be sent to you; or
- give us some feedback on the products and/or services we provide.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources. When we obtain information about you from third parties or publicly available sources rather than from you directly, we will notify you of any relevant information obtained, for example, the type of personal data, within a reasonable period.
Information collected from you about other people
When you provide personal information to us relating to any of your officers, employees or other representatives, you confirm that you are authorised to do so and you should ensure that this privacy notice is brought to the attention of such individuals to ensure that those individuals understand how their personal data will be used by us.
Our 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.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- 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.
- Where we need to comply with a legal or regulatory obligation.
See below to find out more about the types of lawful basis that we will rely on to process your personal data.
We do not use your information for automated decision making.
Generally, we do not rely on consent as a legal basis for processing your personal data except in those circumstances set out in the table below relating to sending direct marketing communications via email. You have the right to withdraw consent to marketing at any time by following the links on any marketing message sent to you or by contacting us.
Purposes for which e will use your personal data
We have set out below, in a table format, a description of all the ways we may use 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To communicate with you in connection with our products and/or services, for example, responding and dealing with your enquiries and requests||(a) Identity
|(a) Performance of a contract with you where we have contracted directly with you as a sole trader or a general or limited partnership
(b) Necessary for our legitimate interests where you are acting on behalf of a company or a limited liability partnership (LLP) (to enable us to take instructions and understand the requirements of the company or LLP and provide estimates in terms of the scope of work involved)
|To deliver products and/or services to you where we have contracted directly with you or to deliver products and/or services to your company/LLP where you are acting on its behalf||(a) Identity
|(a) Performance of a contract with you where we have contracted directly with you as a sole trader or a general or limited partnership
(b) Necessary for our legitimate interests where you are acting on behalf of a company or an LLP (to enable us to perform the contract entered into with your company or LLP and provide the best possible service)
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal or regulatory obligation
|To use data analytics to improve our website, services, marketing, client relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of clients for our products and/or services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you by email about business services that may be of interest to you/your business||(a) Identity
(e) Marketing and Communications Data
|(a) Your consent to the processing where you are a sole trader or a general or limited partnership and have not bought (or negotiated to buy) a similar product or service but you have specifically requested information from us
(b) Necessary for our legitimate interests (to develop our products and services and grow our business) where (i) you are a sole trader or a general or limited partnership and have bought (or negotiated to buy) a similar product or service from us and have not opted out of marketing messages or (ii) you are a representative of a company or an LLP which is an existing client of ours and have not opted out of marketing messages
We have set out below further information on the meaning of each of the legal bases for processing set out in the third column of the table above:
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to provide the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means processing your personal data where you have provided a freely given, specific, informed and unambiguous indication of your agreement to us processing your personal data.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing. You will only receive marketing communications from us if we have a lawful basis for sending such marketing, details of which can be found in the table above.
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 contacting us at any time.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with selected people or organisations for the purposes set out in the table in paragraph 4 above. This will include, but is not limited to, sharing personal data with:
- Service providers acting as processors or joint controllers who provide IT and system administration services (including back-office support) and marketing platforms.
- 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 notice.
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.
Some of our external third parties are based outside the European Economic Area (EEA) so 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 ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe or use contractual clauses authorised by the ICO or such other competent supervisory authority.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place 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 to those employees, agents, contractors and other third parties who have a business need to know. 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.
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.
Details of retention periods for different aspects of your personal data are available in our retention policy, a copy of which is available upon request by contacting us.
In some circumstances you can ask us to delete your data: see ‘Request erasure’ below for further information.
Furthermore, in some circumstances we may 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.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a “data 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. 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) 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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. 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will have to pay a fee to access your personal data (or to exercise any of the other rights). If your request is clearly unfounded, repetitive or excessive, Alternatively, we may 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 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.