1. Introduction
1.1 We are committed to safeguarding the privacy of our service users. “Personal data” is defined in Article 4(1) of the GDPR:
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our service users; in other words, where we determine the purposes and means of the processing of that personal data.
personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.3 In this policy, “we”, “us” and “our” refers to PracticalHistories.com. For more information about us, see Section 12.
2. How we use your personal data
2.1 In this Section 2 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.
2.2 We may process information contained in any enquiry you submit to us regarding our services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or the taking steps, at your request, to enter into such a contract.
2.3 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 notifications and/or newsletters. The legal basis for this processing is consent.
2.4 We may process personal information. This data may include, but may not be limited to names, dates of birth, email addresses and passport details. The source of this data is our clients and potential clients. This data may be processed for the purposes or organizing events. The legal basis for this processing the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.5 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense 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.
2.6 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.7 In addition to the specific purposes for which we may process your personal data set out in this Section 2, 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.
3. Providing personal data to others
3.1 We may disclose 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 establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.2 Personal data held in our database.
3.3 We may disclose personal data to our suppliers or subcontractors insofar as reasonably necessary for the purpose of organising an event.
3.4 In addition to the specific disclosures of personal data set out in this Section 3, 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 personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of- court procedure.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 The hosting facilities for our website are situated in the UK. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
4.3 You acknowledge that personal data that you submit through our website may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section 5 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.
5.2 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.
5.3 We will retain your personal data as follows:
(a) personal data will be retained for a minimum period of 30 days following the date of collection, and for a maximum period of 30 days following the final reconciliation of any event.
(b) enquiry data will be retained for a minimum period of 30 days following the date of the enquiry, and for a maximum period of 3 years following that date.
5.4 Notwithstanding the other provisions of this Section 5, 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.
6. Your rights
6.1 In this Section 6, we have listed the rights that you have under data protection law.
6.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask use to restrict the processing of personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
6.3 These
can be found at https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data- protection-regulation-gdpr/individual-rights/
rights are subject to certain limitations and exceptions. Details about the rights of data subjects
6.4 You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
7. Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We will notify you of significant changes to this policy by email.
8. Our details
8.1 Contact address Oakbank, Upper Moors Road, Brambridge, Hampshire, UK, SO21 1RY
8.2 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by email, using the email address published on our website or provided by us.
9. Data protection officer
9.1 Our data protection officer’s contact details are: Richard McFahn, [email protected]