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Privacy Policy

Privacy Policy

1          Introduction

1.1       Castle Associates (“We”) are committed to safeguarding and respecting your privacy.

1.2       This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data of [our website visitors and service users] we collect from you, or that you provide to us, where we determine the purposes and means of the processing of that personal data.

1.3       Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. We keep certain basic information when you visit our website and recognise the importance of keeping  information secure and letting you know what we will do with it.

1.4       We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of [our website visitors and service users], we will ask you to consent to our use of cookies when you first visit our website. castleassociates.org.uk

1.5       For the purpose of the Data Protection Act 1998 (the Act), the data controller is Castle Associates of Castle Associates, Head Office, 28A Musters Road, West Bridgford, Nottingham, NG2 7PL (registration number Z3538174).

1.6       This policy only applies to our website visitors and service users. If you leave our site via a link or otherwise, you will be subject to the policy of that website provider. We have no control over that policy or the terms of the website and you should  check their policy before continuing to access the site.

2          Information we may collect from you

2.1       We may collect and process the following data about you:

            Information that you provide by completing the forms on our site http://castleassociates.org.uk (our site). This includes information provided at the time of registering to use our site, subscribing to our service or requesting further services.We  may also ask you for information when you report a problem with our site.

            If you contact us, we may keep a record of that correspondence.

            We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.

            Details of your visits to our site including, but not limited to, traffic data, location data, weblogs, operating system, browser usage and other communication data, whether this is required for our own billing purposes or otherwise and the            resources that you access.

3          IP addresses and cookies

3.1      We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers.

3.2      This is statistical data about our users’ browsing actions and patterns, and does not identify any individual and we will not collect personal information in this way.

3.3     We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive.

         They help us to improve our  site and to deliver a better and more personalised service. They enable us:

         To estimate our audience size and usage pattern.

         To store information about your preferences, and so allow us to customise our site according to your individual interests.

         To speed up your searches.

         To recognise you when you return to our site.

3.4     You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your  browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

4        How we use your personal data

4.1    In this Section 4 we have set out:

(a)      the general categories of personal data that we may process;

(b))    the purposes for which we may process personal data; and

(c)      the legal bases of the processing

4.2     We may process data about your use of our website and services ("usage data") section 3.

4.3     We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is both consent and our legitimate interests, namely the proper adminstration of  our website and business including legal obligations and the defence of possible legal claims.

4.4     We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include your name and email address. The source of the service data is you. The service data may be processed for the purpose of providing our services, ensuring the security of our, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent and our legitimate interests, namely the proper administration of our business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

4.5    We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

4.6    We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you.

The customer relationship data may be processed for the purposes of  managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers.

The legal basis for this processing is consent and our legitimate interests, namely the proper management of our customer relationships.

4.7    We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details  and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.

The legal basis  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 and our legitimate interests, namely the proper administration of our website and business.        

4.8    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant nottifications and/or newsletters. The legal basis for this processing is consent and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

4.9    We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the  communication. Our website will generate the metadata associated with communications made using the website contact forms.

The correspondence data may be processed for the purposes of communicating with you and record-keeping.

The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

4.10   We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

4.11   In addition to the specific purposes for which we may process your personal data set out in this Section 4, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are  subject, or in order to protect your vital interests or the vital interests of another natural person.

4.12   Please do not supply any other person's personal data to us, unless we prompt you to do so.

5.       Providing your personal data to others

5.1     We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the stablishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.2     We may disclose your contact information to our subcontractors insofar as reasonably necessary for the purpose or provide our service. The legal basis 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 and our legitimate interests, namely the proper administration of our business.

5.3     Financial transactions relating to our website and services are may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.

5.4    In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital  interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

6.       International transfers of your personal data

6.1     In this Section 6, we provide information about the circumstances in which your personal data may be transferred to [countries outside the European Economic Area (EEA)].

6.2     We will not be processing or transferring your personal data outside EEA.

7.       Retaining and deleting personal data

7.1     This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

7.2     Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

7.3     We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

8.       Amendments

8.1     We may update this policy from time to time by publishing a new version on our website.

8.2     You should check this page occasionally to ensure you are happy with any changes to this policy.

 

9.       Your rights

9.1     In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

9.2     Your principal rights under data protection law are:

(a)      the right to access;

(b)      the right to rectification;

(c)      the right to erasure;

(d)     the right to restrict processing;

(e)     the right to object to processing;

(f)      the right to data portability;

(g)      the right to complain to a supervisory authority; and

(h)      the right to withdraw consent.

9.3     You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of    charge, but additional copies may be subject to a reasonable fee.

9.4     You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

9.5     In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise      processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for the establishment, exercise or defence of legal claims.

9.6     In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer  need the personal    data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

9.7     You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the  performance of a task    carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment,exercise or defence of legal claims.

9.8     You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal   data for this purpose.

9.9     To the extent that the legal basis for our processing of your personal data is:

(a)      consent; or

(b)      that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

(c)      Legitimate interest,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it  would adversely affect    the rights and freedoms of others.

9.10   If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of      your  habitual residence, your place of work or the place of the alleged infringement.

9.11   To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

9.12   You may exercise any of your rights in relation to your personal data by written notice to us or by email.

 

10.     Our details

10.1   This website is owned and operated by Castle Associates.

10.2   We are registered in [England and Wales] under registration number [number], and our registered office is at 28A Musters Road, West Bridgford, Nottingham, NG2 7PL.

10.3   Our principal place of business is at 28A Musters Road, West Bridgford, Nottingham, NG2 7PL.

10.4   You can contact us:

(a)      by post, to the postal address given above;

(b)      using our website contact for;

(c)      by telephone, on the contact number published on our website from 9 am to 5 pm; or

(d)     by email, using the email address published on our website from time to time.

 

11.     Credit

11.1   This document was created using a template from SEQ Legal (https://seqlegal.com).

 

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