INTRODUCTION & GENERAL TERMS
Our Commitment to you
We may use third party suppliers to provide part of our service to you. In some circumstances these providers may be based in countries outside the European Economic Area whose laws provide for a different standard of protection for your personal information than that provided under UK Law. In such circumstances:
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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
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.
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 the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
If you would like further information about the specific mechanism, used by us when transferring your personal data out of the EEA please contact: [email protected]
Your personal data will not be disclosed to state institutions and authorities except if required by law or other regulation. Before we release data on this basis, we will ensure that the information is being provided to a genuine and properly authorised investigation.
WHO WE ARE
PATRA Inc ACDA which is registered in England and Wales under charities commission number 518376 is the controller and responsible for your personal data collected by Kutambua. We have appointed a data privacy 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 privacy manager using the details set out at the end of this document.
Changes to The Privacy Notice and Your Duty to Inform Us of Changes
This version was last updated on 23rd June 2021.
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 by contacting [email protected].
WHAT DATA WE COLLECT
When you send us information, talk to us over the phone, submit an online form or when you visit one of our websites, we may collect both pseudonymous data about you. When we talk about data, we mean any information that can identify you as an individual, such as your name and postal address. Pseudonymous data doesn’t identify you as a person, but it might be used in aggregate, for instance when you participate in a survey or when we analyse audience interaction with our products and services.
When you visit and use our website or request our services you may provide us with or we may collect your Information such as your postal address, email address and other personal information. You may provide or we may collect this Information in a number of ways:
Information you voluntarily provide to us
We collect and maintain Information that you voluntarily submit to us during your use of our website or services. For example:
When you register on our website or for a service, you may provide us with certain Information including your name, email address and contact numbers
If you sign up to receive a newsletter or a magazine, you may provide us with contact information (e.g., email, telephone and/or or physical address)
You may provide us with Information in the course of email, customer support interactions and surveys.
Different websites operated by us may ask for different pieces of Information. You can choose not to provide us with certain Information, but this may stop you from gaining access to a service or limit the features that you can use on our websites. For more information, please see the “How We Use Your Information” section of the Policy below.
Information we collect through your use of our website
Information we receive from third parties
We may also combine online and/or offline information received from third parties (including other members of our group of companies) with your Information. The third-party information is used for a variety of purposes including to verify other Information about you (e.g., verify your mailing address to send you requested products or services) and to enhance the content and advertising we provide to you.
If you are the parent or guardian of a child under 13 (“Child” or “Children”) and have provided us with information belonging to a Child, then alongside the Child’s data provided, we may also process limited personal data about you, so we can record your consent to store, process and use this information about the Child to fulfil the service you have purchased or signed up to on their behalf. We may use your contact details to communicate with you about the Child’s use of these products or services. We will never knowingly send marketing communications to a Child under the age of 13. If you believe we have collected personal information about your Child without your consent, you may contact us at [email protected] and request that we remove information about your Child.
HOW WE USE YOUR DATA
We may use the information you share with us and the information we collect through your use of our sites in the ways described below and as described at the time of capture.
To Provide the Services
In general, we use your Information as necessary or appropriate for our business purposes including to:
Administer your account where you have opened an account with us
Register you and provide you access to the website or services requested by you
Respond to inquiries or requests that you direct to us
Fulfil your requests for products or services
Send communications and administrative emails about the website or our services
Personalise and better tailor the features, performance and support of the website and our services for your use; analyse, benchmark and conduct research on user data and user interactions with the website and our services
Other purposes related to any of the above
We will use the details you have shared to send you the newsletter to which you have subscribed. We will not add them to any marketing lists unless you have consented to this. We will provide a way for you to unsubscribe on every newsletter we send to you. Details you share with us for the purpose of newsletter subscription will never be shared with a third party.
We will use the details you have shared to manage your registration and entry into our event. This may include contact via telephone, email, SMS and post with information relating to the event you have registered to attend. Your data will not be added to any marketing lists unless you have consented to this and will only be shared with a third party where they were named at the point of data capture and you explicitly agreed to the sharing of your data or where they are a third party who we have appointed to manage the delivery of the event.
Marketing and research
Where you have provided us with the appropriate consents, or where the Act entitles us to do so, we may send you marketing materials about other products or services offered by us, and/or products or services offered by our group companies. In addition, where you have provided us with the appropriate consents, we may also pass your Information to one or more of our group companies or other selected third parties for marketing purposes. However, be assured that we understand the irritations of unsolicited communications and we are fully committed to ensuring the rights and obligations set out in the Act and the Privacy and Electronic Communications Regulations 2003, updated 2004 and 2011 are respected.
What Personal Information Kutambua Holds on Me?
Under the Act you have the right to request a copy of the Information that we hold about you. There will be an administration fee of £10 associated with this request and it will require two pieces of identification to prove your identity. Please make a written application to the Data Protection Officer, PATRA Inc ACDA (Kutambua Project), Lenton Business Centre, Lenton Boulevard, Nottingham, NG7 2BY.
HOW WE DISCLOSE YOUR INFORMATION TO THIRD PARTIES
We may share your Information with third parties as specifically approved by you or under the circumstances described below.
Disclosure for legal reasons
We may disclose your Information if we are under a duty to disclose or share your Information to comply with any legal obligation or in order to enforce or apply or fulfil our terms and conditions and other agreements or protect the rights, property, or safety of our customers, our group companies or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.
We use a number of third-party organisations to help provide a professional service to our customers and service users including other charities, government agencies and statutory bodies and website designers. These organisations act as data processors and are strictly controlled in how they may/may not use your Information and we remain responsible for the protection of your Information.
Changes to our organisation
In the event we go through a business transition such as a merger, acquisition by another company or charity, or sale of all or a portion of our assets, your Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Policy.
UPDATING AND CONTROL OF YOUR INFORMATION
There are a number of ways in which you can control the collection, use, and sharing of your Information and update your Information and preferences.
Opting Out on Receipt of Marketing Communications
When you receive marketing communications from us you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the marketing e-mail or newsletter.
If your information has changed or if you no longer wish to receive marketing communications from us, then please contact us to update your information.
Please note that:
- Even if you delete Information, we may retain your Information in conformance with our data retention policy; and
- We are not responsible for updating or removing your Information contained in the lists or databases of third parties who have been provided with Information as permitted by this Policy.
THIRD PARTY LINKS AND SERVICES
Please remember that when you use a link to go from our website to another website or you request a service from a third party, our Policy no longer applies. Your browsing and interaction on any other website or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. We do not monitor, control, or endorse the information collection or privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to information collected by us through our website or services and does not apply to these third-party websites and third-party service providers.
WHERE WE STORE YOUR INFORMATION
The Information that we collect from you may be transferred to, stored and processed at a destination outside the European Economic Area, (all EU countries plus Norway, Iceland and Liechtenstein). Your Information may also be processed by staff operating outside the EEA who work for us or for one of our suppliers, for instance, for customer service purposes. By submitting Information to us, you agree to this transfer, storing or processing. We will take all steps reasonably necessary, including the use of the Model Contractual Arrangements as approved by the EU, or other contractual means to ensure that your Information is treated securely and in accordance with this Policy and the Act.
HOW LONG WE KEEP YOUR PERSONAL DATA FOR
We will hold your personal information on our systems only for as long as required to provide you with the products and/or services you have requested.
Where you sign up to receive email marketing from us, we will retain your e-mail address after you ‘opt-out’ of receiving emails in order to ensure that we continue to honour and respect that request. To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email and update your account preferences. You may also contact us to inform us if you do not wish to receive any marketing materials from us.
In some circumstances you can ask us to delete your data: see ‘Your rights’ below for further information.
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.
SECURITY OF YOUR INFORMATION
We follow appropriate security procedures in the storage and disclosure of your Information to prevent unauthorised access by third parties. We also require those parties to whom we transfer personal information to comply with the same. However, unfortunately, the transmission of information via the Internet is not completely secure. So, we cannot ensure the security of your Information transmitted by you to us via the internet. Any such transmission is at your own risk and you acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of your Information, except to the extent we are required to accept such responsibility by the Act. Once we have received your Information, we will use security procedures and features to prevent unauthorised access to it.
We do not control how your personal information is collected, stored or used by such third-party sites or to whom it is disclosed. You should review the privacy policies and settings on any social networking site that you subscribe to so that you understand the information they may be sharing. If you do not want your networking sites to share information about you, you must contact that site and determine whether it gives you the opportunity to opt-out of sharing such information. We are not responsible for how these third-party sites may use information collected from or about you.
PERSONAL DATA – YOUR RIGHTS
Under the GDPR including any implementing data protection legislation in the UK you have the rights shown below:
Your right to be informed
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
Where we process your personal data on the basis of a legitimate interest (see the How we use your data section of this Policy which explains why we use your personal data) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.
You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us to verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party, we are happy to consider such requests.
Your Right to stop receiving communications
For details on your rights to ask us to stop sending you various kinds of communications, please contact us.
Your Right to object to automated decision making and profiling
You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Exercising your rights
If you wish to exercise any of these rights or simply wish to find out what information, if any, we hold that relates to you, you must make your request in writing as per the contacts below.
CONTACT OUR DATA PRIVACY TEAM
Full name of legal entity: PATRA Inc ACDA, Kutambua Project
Email address: [email protected]
Postal address: Lenton Business Centre, Lenton Boulevard, Nottingham, NG7 2BY
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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
If we decide to change our Privacy Notice we will post these changes on this page so that you are always aware of what information we collect, how we use it and in what circumstances we disclose it.