Last Update: 27th August 2019
Your privacy is important to us and we are committed to protecting the privacy of our users and the information that you share in connection with Our Site. We respect and value the privacy of everyone who visits Our Site and uses Our Services. We will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our Obligations under the law.
(i) what information we collect;
(ii) how we process and manage such information;
(iii) your rights with respect to the use and disclosure of the same.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
Service User: means an adult or young person that makes use of Our Services related to programmes, workshops, events and courses. Our service users includes the young people that benefit from Our Services as well as any parents, carers, teachers, volunteers, funders, agencies or other any other adult that support them.
Cookies: means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site.
Our Site: refers to this website, www.gtscholars.org
Our Services: refers to any activity conducted by GT Scholars CIC in order to meet our incorporated aims and objectives. This can include workshops, interviews, meetings, newsletters, email and telephone campaigns, training courses, fundraising, marketing activities, events, courses, excursions, programmes and any other activity that is essential to achieving our business aims and objectives.
We/Us/Our: means GT Scholars CIC, a not for profit community interest company limited by guarantee registered in England under Company Number 09816263 , whose registered address is GT Scholars CIC 89-90 Paul Street, London EC2A 4NE
Personal Data: means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, email address, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), as well as any other non-public information about you that is associated with or linked to any of the foregoing data.
Non-Personal Data: means data that is not associated with or linked to your Personal Data; Non-Personal Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Non-Personal Data, as described below.
Scope – What Does This Policy Cover?
We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to such websites.
What Data Do We Collect?
Some data will be collected automatically by Our Site, other data will only be collected if you voluntarily submit it and consent to Us using it for Our Services.
Depending upon your use of Our Services, We may request some or all of the following data: Name; Date of Birth; Gender; Profession; School name; Business name; University name; Employer Name; Proof of ID, Criminal Record Checks (DBS certificate); Photographs and Images; Academic attainment; Proof of Income for bursaries, Contact information such as email addresses and telephone numbers, Academic and Employment History and Demographic information such as postcode, preferences and interests.
In addition to this, Our Site may automatically collect some or all of the following data:
- Information Collected by Our Servers. To make Our Site more useful to you, our servers (which may be hosted by a third-party service provider) collect information from you, including your browser type, operating system, domain name, and/or a date/time stamp for your visit.
- Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor Our Site to our users’ needs. For example, some of the information may be collected so that when you visit the Site again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. We do not link this automatically-collected data to Personal Data.
- Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send email messages in a format users can read, and they tell us whether emails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to users. We do not tie the information gathered by Pixel Tags to Personal Data.
- Flash LSOs. When we post videos, third parties may use local shared objects, known as “Flash Cookies,” to store your preferences for volume control or to personalize certain video features. Flash Cookies are different from browser Cookies because of the amount and type of data and how the data is stored. Cookie management tools provided by your browser will not remove Flash Cookies. To learn how to manage privacy and storage settings for Flash Cookies, click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
How Do We Use Your Data?
All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). Under the GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights.
We use your data to provide Our Services to you. We may also use your data to personalise and tailor Our Services to you; we may share your data with third party subcontractors or volunteers that supply Our Services to you such as tutors, mentors, workshop facilitators, programme managers and event managers.
We may use your data to respond to communications from you; supply you with newsletters, alerts and updates that you have subscribed to, conducting market research; Analyse your use of Our Site and gather feedback to enable Us to continually improve Our Site and your user experience.
In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services we can provide you without your consent for Us to be able to use such data.
With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone or text message with information, news and offers on Our Services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that
We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011, 2015 and 2016.
We may share your Personal Data when we believe disclosure is necessary or required by law, regulation, to protect users, the integrity of the Site and to defend or exercise our legal rights. We may also disclose your Personal Data when it may be necessary for other legitimate and lawful purposes as reasonably determined by us.
As set out in Article 6 of GDPR, We will only process your personal data if at least one of the following basis applies:
(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).
(d) Vital interests: the processing is necessary to protect someone’s life.
(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
(f) Legitimate interests: the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
How and Where Do We Store Your Data?
We only keep your data for as long as we need to in order to provide Our Services to you, and/or for as long as we have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data.
You may exercise your right to delete your data at any point in time. Your data will also automatically be deleted if we no longer need it in accordance with the terms of our Data Retention Policy which can be found here: https://gtscholars.org/data-retention-policy/
Some of our third party service providers and their servers are located in the United States and other countries outside of the EU and therefore your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by continuing to use Our Site, use Our Services and/or submitting information to Us.
For all data that is stored or transferred outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties.
We maintain (and require our subcontractors and service providers to maintain) appropriate organizational and technical measures designed to protect the security and confidentiality of any information we process. When personal information is shared, transferred or stored internationally, we put in place safeguards in accordance with applicable law (including Articles 44 to 50 of the EU General Data Protection Regulation).
Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site. Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting data to Us via the internet.
You may have rights under UK laws, European laws and other laws to have access to your personal information and to ask us to rectify, erase and restrict use of your personal information. You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us and to withdraw consent to the use of your personal information. Further information on how to exercise your rights is set out below.
We will honor your rights under applicable data protection laws. You have the following rights under European laws, and may have similar rights under the laws of other countries.
- Right of subject access: The right to make a written request for details of your personal information and a copy of that personal information
- Right to rectification: The right to have inaccurate information about you corrected or removed
- Right to erasure (‘right to be forgotten’): The right to have certain personal information about you erased
- Right to restriction of processing: The right to request that your personal information is only used for restricted purposes
- Right to opt out of marketing: You can manage your marketing preferences by using the unsubscribe links found in the communications you receive from us or by visiting the applicable preference center
- Right to object: The right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have notified you that the processing is necessary for our or a third party’s legitimate interests
- Right to data portability: The right to ask for the personal information you have made available to us to be transferred to you or a third party in machine-readable format
- Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent
We will always process your requests in accordance with applicable data protection laws. If you would like to exercise any of these rights, please contact us so that we may consider your request in accordance with applicable laws.
These rights are not absolute and they do not always apply in all cases. In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If we do not comply with your request, whether in whole or in part, we will explain why.
Do We Share Your Data?
In order to supply Our Services to you, we may work with third parties who may have access to some of your personal data. This may include sharing your personal details with a course provider, venue providers, workshop facilitators and event coordinators.
For example, for parents, we may share your details with an assigned mentor or tutor or volunteer supporting your child with his or her academic progress. Likewise, for volunteers or staff, we may share your personal details with a parent and his or her child so that he or she may contact you.
Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that We limit any personal data so that only essential and necessary data is shared. We will also ensure that your data will be handled safely and securely in accordance with your rights, Our Obligations, and the obligations of the third party under the law.
Our third-party service providers are not permitted to share or use personal information we make available to them for any purpose other than to provide services to us.
We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, funders, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
In certain circumstances, we may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
How Can You Control Your Data?
When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong control over Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails, by changing your contact preferences and/or by contacting us directly via email.
You may also wish to sign up to one or more of the preference services operating in England such as The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receive.
Your Right to Withhold Information or Withdraw Information After You Have Given it
How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us.
You may contact us by emailing firstname.lastname@example.org
Automated Decision-Making and Profiling
In the event that we use your personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant) effect on You, You have the right to challenge such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
The right described above, does not apply in the following circumstances:
- The decision is necessary for the entry into, or performance of, a contract between You and Us;
- The decision is authorised by law; or
- You have given you explicit consent.
In the event that we use your personal data for profiling purposes, the following shall apply:
- a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
- b) Appropriate mathematical or statistical procedures will be used;
- c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
- d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.