1. About this Policy
1.1 This policy explains when and why we collect personal information about our Associates, how we use it and how we keep it secure and your rights in relation to it.
1.4 We will always comply with the General Data Protection Regulation (GDPR) when dealing with your personal data. Further details on the GDPR can be found at the website for the Information Commissioner (www.ico.org.uk). For the purposes of the GDPR, we will be the “controller” of all personal data we hold about you.
2. Who are we?
2.1 We are the Galpeg Limited. We can be contacted at 70 Hampden Road, London N10 2NX. Tel: 020 8444 4455 or by email to email@example.com
3. What information we collect and why
Type of information
Legal basis of processing
Associates’ name, address, telephone numbers, e-mail address(es).
Managing the Associates’ representation of the Company
Creating and managing the Company’s online Associateship Directory.
Managing the club rosters.
Performing the Company’s contractual obligations with customers introduced by Associates.
For the purposes of our legitimate interests in operating the Company.
Consent. We seek the Associates’ agreement in the terms of the signed Associate Agreement. The Associate may withdraw their consent at any time by contacting us by e-mail or letter to tell us that they no longer wish their details or the details of customers introduced by the Associate to the Company to be held by the Company.
Provision of adequate facilities for Associates.
For the purposes of our legitimate interests in making sure that we can provide sufficient and suitable facilities (including toilets) for each gender.
Photos and videos of Associates
Putting on the Company’s website and social media pages and using in press releases.
Consent. We will seek the Associates’ consent on their Associate Data Consent Form and the Associate may withdraw their consent at any time by contacting us by e-mail or letter.
4. How we protect your personal data
4.1 We will not transfer your personal data outside the EU without your consent.
4.2 We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
4.3 Please note however, that where you are transmitting information to us over the internet this can never be guaranteed to a 100% secure.
4.4 We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.
5. Who else has access to the information you provide us?
5.1 We will never sell your personal data. We will not share your personal data with any third parties without your prior consent (which you are free to withhold) except where required to do so by law or as set out in the table above or paragraph 5.2 below.
5.2 We may pass your personal data to third parties who are promotional product suppliers, agents and subcontractors to use for the purposes of completing tasks and providing services to you on our behalf (e.g. to send you mailings and product information). However, we disclose only the personal data that is necessary for the third party to deliver the service and we have a non-disclosure agreement in place that requires them to keep your information secure and not to use it for their own purposes.
6. How long do we keep your information?
6.1 We will hold your personal data on our systems for as long as you are an Associate of the Company and for as long afterwards as is necessary to comply with our legal obligations. We will review your personal data every year to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing your personal data except that we will
retain your personal data in an archived form in order to be able to comply with future legal obligations e.g. compliance with tax requirements and exemptions or defence of legal claims.
6.2 We securely delete/destroy all information once we have used it and no longer need it.
7. Your rights
7.1 You have rights under the GDPR:
(a) to access your personal data
(b) to be provided with information about how your personal data is processed
(c) to have your personal data corrected
(d) to have your personal data erased in certain circumstances
(e) to object to or restrict how your personal data is processed
(f) to have your personal data transferred to yourself or to another party in certain circumstances.
7.2 You have the right to take any complaints about how we process your personal data to the Information Commissioner:
0303 123 1113.
Information Commissioner’s Office, Wycliffe House,
Water Lane, Wilmslow,
Cheshire SK9 5AF
For more details, please address any questions, comments and requests regarding our data processing practices to our Data Controller at; firstname.lastname@example.org.