Privacy Policy

Your privacy is important to us - Privacy Information

We are committed to protecting your personal data and your privacy. This privacy notice aims to give you information on how we collect and process your personal data through your use of our website (www.glasgowgirlsclub.org) or any other websites and apps registered in our name ("Websites and Apps"), including any personal data that you may provide through our Websites and Apps, where we have a contract in place with you (please note that separate terms and conditions may also be applicable here), through your use of our services ("Services") and through your other communications with us.

It is important that you read this privacy notice when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data.

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.

This version of our privacy notice was last updated on the 18th May 2021.

What does this privacy policy govern?

This privacy policy applies to our “websites and apps” - any app or service (downloadable or via URL) - we offer directly (and via our clients) and another other services that we may provide to you through our “website and apps” or “services”. In the context of this Privacy Policy, “personal information” is defined as information which, on its own or combined with other information, can be used to identify you, in particular reference to an identifier such as your name, your address or data on location. The personal information that you provide, or that we collect from you, is held under data protection legislation. This legislation requires that we tell you that we are a data controller for your personal information, i.e. we determine the purposes for which and the manner in which any of your personal information are, or are to be, processed by us.

This privacy notice applies to:

  • all individuals who use our Services.
  • all individuals who visit our Websites and Apps.

Who we are

We are Glasgow Girls Club CIC, a company incorporated in Scotland with registered number SC480468 and having our registered office address at 505 Great Western Road, Glasgow, Scotland, G12 8HN.

We are a controller for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679) and related data protection legislation.

Information about our websites and apps

Our Websites and apps 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 we are not responsible for their privacy statements. When you leave our Websites and apps, we encourage you to read the privacy notice of every website you visit.

About the personal data that we collect and process

"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 do not collect or process special categories of personal data in the course of providing our Services.

This policy summarises the personal data we collect and process, how we use it ("our processing purposes") and why we use it ("the lawful bases of processing").

We may 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 data to calculate the percentage of individuals accessing a specific feature of our Websites and Apps, or to analyse how individuals use our Services. 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.

How is your personal data obtained?

We use different methods to collect personal data from and about you including through:

  • Direct interactions. You may give us your identity, contact, financial, transactional or similar personal data when you correspond with us by post, phone, e-mail or otherwise, including when you use our Services, complete a form on our Websites and Apps or otherwise contact us via our Websites or Apps.
  • Direct interactions with business contacts, individual clients and client-related individuals. You may give us your identity, contact, financial, transactional and other business related personal data when you correspond with us, including when:
  • you or your organisation negotiate and/or enter into a contract with us; or
  • you or your organisation provide services or products to us or your or your organisation receive services from us; or
  • you provide us with your business card.
  • Direct interactions with our investors and/or shareholders. You may give us your identity, contact and other business related personal data in the process of investing in Glasgow Girls Club CIC or where you communicate with us as a shareholder in Glasgow Girls Club CIC.
  • Automated technologies or interactions. As you interact with our Websites and Apps or use our Services, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
  • where you are a business contact, your organisation or business may provide us with your identity and contact data.
  • where you are a client-related individual, your organisation or business may provide us with your identity and contact data.
  • we may obtain identity and contact data from publicly available sources such as social media (such as LinkedIn or Twitter), Companies House or other organisations’ websites.
  • we may obtain technical data (relating to the use of our Websites and Apps, and Services) from analytics providers or search information providers.

Failure to provide personal data

Where we need to collect personal data by law, to provide our Services, or under the terms of a contract we have with you (or are trying to enter into with you) and you fail to provide that data when requested, we may not be able to perform the contract or perform our Services. In this case, we may have to cancel a contract (but we will notify you if this is the case at the time) and/or be unable to provide our Services.

Marketing

If you are an individual consumer or end user, we will only provide you with direct marketing communications where you have consented to receive such communication or you have contacted us directly to request specific information about our Services. You can subscribe to such marketing communications, and you can adjust your marketing preferences at any time by contacting us at ([email protected])

If you represent another business or organisation, we may provide you with direct marketing communications where we feel that this may be relevant to your business (provided that you have not opted out of such communications). When we use your personal data for such purposes, we do so on the basis that it is in our legitimate interests to pursue direct marketing, provided that it constitutes fair processing of your personal data to do so.

You can also opt-out or unsubscribe from all or some of these marketing communications at any time by contacting us at ([email protected])

Where you opt out of receiving these marketing communications, this opt-out will not apply to personal data provided to us for any other purpose.

With whom do we share your personal data?

There may be circumstances in which we may need to share your personal data with certain third parties (strictly on a confidential, business need-to-know basis). The third parties to which we may transfer your personal data include:

  • Your business or organisation, for the purpose of providing our Services to your business or organisation, or receiving products or services from your business or organisation.
  • Our corporate customers where you are an end user.
  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, accountants, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • Any relevant accreditation body or trade association.
  • Any relevant regulatory authority or law enforcement agency, including HM Revenue & Customs, courts or tribunals who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to 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.

Any sharing of your personal data will only take place either where we are legally obliged to do so, where it is necessary for the performance of a contract with you or where it is in our legitimate interests to do so, including as follows:

  • to maintain network and information security;
  • to provide Services to our clients;
  • to develop and improve our Services in order to remain competitive;
  • to establish, protect and defend our legal rights;
  • to pursue our commercial objectives where this does not override your rights and freedoms as a data subject

International transfers

We generally do not transfer your personal data out of the European Economic Area (EEA). However, whenever we are required to transfer your personal data out of the EEA (for example where a third party supplier is located outside of the EEA), we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented, including any of the following:

  • We will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en).
  • 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. For further details, see European Commission: Model contracts for the transfer of personal data to third countries (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en).
  • Where we use providers based in the USA, 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 the European Union and the USA. For further details, see European Commission: EU-US Privacy Shield (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_en).
  • You have provided your explicit consent to the transfer of your personal data outside of the EEA.
  • The transfer is necessary for the purposes of performing a contract between us and you (the data subject).

Automated decision making and profiling

We do not use automated decision-making (including profiling) to make any decisions which would produce a legal effect or similarly significantly affect a data subject.

How long do we retain your personal data?

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.

Personal data relating to Website and App users, end users and business contacts will generally not be retained for longer than 12 months unless such data is relevant to ongoing Services. Personal data relating to individual clients and client-related individuals will generally not be retained for longer than 7 years after conclusion of the relevant services unless such data is relevant to any legal, accounting or reporting requirements. Please contact us at ([email protected]) for further details about our retention periods.

Data security

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 the Information Commissioner's Office of a breach where we are legally required to do so.

Your rights

Data protection laws grant you, as a Data Subject, certain ‘information rights’ which are summarised below:

  • 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. 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, following 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. You also have the right to object where we are processing your personal data for direct marketing purposes.
  • 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: if you want us to establish the data's accuracy; where our use of the data is unlawful but you do not want us to erase it; 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 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 (data portability). 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 these rights, please contact us at ([email protected]).

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.

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. Alternatively, we may refuse to comply with your request in these circumstances.

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.

You also have the right to complain to the Information Commissioner's Office, which regulates the processing of personal data, about how we are processing your personal data.

Personal Data

Personal data will be processed by us where you consent to the processing or where that processing is necessary for 1) the performance of a contract with you; or 2) compliance with a legal obligation to which we are subject; or 3) the purposes of our legitimate interests (or those of a third party).

We have set out below a description of all the ways we might 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 at ([email protected]) 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 below.

End users of our Apps

Individuals who use our Services.

What personal data do we collect?

Technical data - (including internet protocol (IP) address, browser type and version, time zone setting and location, MAC address, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services)

Usage data - (including information about when you used the Services)

How do we use your personal data?

To process and deliver Services to you including:

  • Carrying out our Services; and
  • To improve the user experience and administer the functionality of our Apps.

Website Users

Any visitor to our Websites.

What personal data do we collect?

Technical data - (including internet protocol (IP) address, 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 Services)

Usage data - (including information about your visit and how you use our Services)

How do we use your personal data?

To improve the user experience and administer the functionality of our Websites.

To respond to general and specific enquiries.

Why do we use your personal data?

Necessary for our legitimate interests (to maintain network security and Website relevance for visitors to our Websites and Apps).

Necessary to comply with a legal obligation.

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 at ([email protected]).

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.

Changes to our Privacy Policy

This privacy policy may be changed if necessary for legal reasons, or to reflect changes to our site and services. In any case, the provisions of this Privacy Policy may be changed without prejudice to your rights. When our Privacy Policy is changed, there will be an updated Privacy Policy available to access. Once we change our Privacy Policy, after 30 days of publishing this it will become legally binding on you. During these 30 days, we welcome you to contact us regarding any questions about the changes. If you do not agree with the changes to the Privacy Policy, then we may need to restrict or limit your use of the parts of our Services that require personal information to fully deliver Services to you.

How to contact us

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Initial enquiries should be directed to our Data Protection Officer as follows:

By post: 505 Great Western Road, Glasgow, Scotland, G12 8HN.

By email: [email protected]

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please do contact us in the first instance.