Privacy Policy
Last updated on 02/06/2021
Introduction
This privacy policy applies between you, the user of this website, (you or your) and With Music In Mind CIC, a community interest company limited by guarantee registered with company registration number 12057024 (we or our).
We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights.
1 This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to become a member or book a place at one of our group sessions.
2 This website is not intended for children and we do not knowingly collect data relating to children.
3 It is important that you read this privacy policy so that you are fully aware of how and why we are using your data.
4 We are the controller and responsible for your personal data.
5 If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our information rights officer using the details set out below:
Name: Naomi Hill
Address: 6 Mill Park, Cowbridge, Vale Of Glamorgan, CF71 7BG
E-mail: naomirhill@yahoo.co.uk
6 You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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 contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
7 We keep our privacy policy under regular review. This version was last updated on the date set out above.
8 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.
Third-party links
9 This 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 policy of every website you visit.
The data we collect about you
10 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 or anonymised data).
11 We may collect, use and store different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, title, age and gender.
- Contact Data includes address, email address and telephone numbers.
- Profile Data includes your username and password that will be used to create an account with our online shop and your responses to surveys about new social groups.
We do not share this data with third parties.
12 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users interested in a specific social group or website feature. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, then we will treat the combined data as personal data which will be used in accordance with this privacy policy.
13 We do not collect any Special Categories of Personal Data about you (this includes for example details about your race or ethnicity, religious or philosophical beliefs, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
14 When donating through our website, you will be directed to LocalGiving, a partner organisation that processes donations on our behalf. LocalGiving gather and process any financial information (such as card details) required to make a donation, and you should read their privacy policy for information on how they do this. This financial information is not shared with us.
If you fail to provide personal data
15 Where we need to collect personal data by law, or under the terms of a contract we have with you (for example when you book onto one of our singing and social groups), and you fail to provide that data when requested, we may not be able to complete your booking and guarantee your place. We will notify you at the time if this is the case.
How is your personal data collected?
16 We only collect data from and about you that you directly provide to us. For example, you may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply to become a member;
- book onto one of our singing and social groups;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
17 We do not use cookies to track you interactions with our website and we do not use other automated mechanisms for gathering your personal data.
18 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. For example, where you have provided personal data to:
- register as a member;
- book a place on a social group;
- create an account with our online shop (once this feature is enabled).
- 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. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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).
- Where the processing of your personal data is necessary to comply with a legal obligation to which we are subject.
Marketing & Third Parties
19 We do not share your data with third parties. If we were to propose sharing your data with third parties, we would first get your express opt-in consent.
20 We may from time to time contact you with news and information about us and our activities. If you do not wish to receive these updates please contact us at any time.
Change of purpose
21 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.
22 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.
23 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.
International transfers
24 We do not transfer your personal data outside the UK.
25 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.
26 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.
Data retention
27 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
28 Unless required by law or as set out above, we will generally delete your personal data:
- if the personal data relates to an account you have created with our online shop, after such account has been inactive for 12 months; and
- in any other circumstance, 6 months after your last interaction with us.
29 In some circumstances you can ask us to delete your data: see the Your Legal Rights section below for further information.
30 In some circumstances we will 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
31 You have rights under data protection laws in relation to your personal data. These rights re set our below. If you wish to exercise any of these rights, please contact us.
32 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 could refuse to comply with your request in these circumstances.
33 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.
34 We try to respond to all legitimate requests within one month. Occasionally it could 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.
35 You have the following rights:
- 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. 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.
- 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.
- 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.