1.1. This privacy notice aims to inform you about how Special Needs Today Ltd (referred to as “SNT”, “we”, “us” or “our” in this privacy notice) processes your personal data and tells you about your privacy rights under data protection laws.
1.2. For the purposes of EU data protection laws, we are the ‘controller’ of the personal data we collect about you through and in connection with our operation of the website at www.specialneedstoday.co.uk
How we use your personal data
2.1. In this Section 2 we have set out:
- the general categories of personal data that we process;
- in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
- the purposes for which we may process personal data; and
- the legal bases of the processing.
2.3 Weekly newsletter: we will send this to you unless you tell us that you don’t want to receive it.
2.4 Postal mailing relating to SNT service updates: we will send these to you if you tell us that you want to receive them.
2.5You can opt-in and opt-out to all of the above communications at any time by emailing firstname.lastname@example.org. You can also opt-out from any specific communications by using the unsubscribe facility in the communication itself.
2.6 We will use your email address and/or postal address in order to let you know about our range of products and services for our own internal marketing purposes. This may, for example, include postal mailings about our products and services if you have not visited our website recently. The legal basis for this processing is our legitimate interests, namely to communicate our range of products and services, and improvements to them, to you as a registered user.
2.7 Enquiry data: We will process information contained in any enquiry you submit to us regarding products and/or services advertised on our website, such as when you complete a form requesting more information, a callback or newsletter communications from a range of organisations who use our website to share promotional and/or educational content relating to their products and services. We will process your enquiry data for the purposes of responding to your enquiry, and if you request to be contacted directly by a relevant third party organisation, we will pass the contact details you used to make your enquiry to the relevant third-party organisation for this purpose. The legal basis for this processing is our legitimate interests in communicating with our members and our clients’ legitimate interests in contacting our members where requested by an individual member.
2.8. Correspondence data: We will process information contained in or relating to any communication that you send to us. The correspondence data provided via email or telephone calls may be processed for the purposes of communicating with you, logging your communication and for the management of your account. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.9. Using your personal data for other purposes: 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
- protecting your vital interests or the vital interests of another natural person
- 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)
- the establishment, exercise or defence 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.)
2.10.Other peoples’ personal data: Please do not supply any other person’s personal data to us, unless we prompt you to do so.
Providing your personal data to others
3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
3.2 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Retaining and deleting personal data
4.1 This Section 4 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.
4.2 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.
4.3 Notwithstanding the other provisions of this Section 4, 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.
Security of personal data
5.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
5.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
5.3 Data relating to your enquiries that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
5.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 We may notify you of changes to this policy by email or through the website. 9. Your rights
6.3 In this Section 6, we have summarised the rights that you have under data protection law. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
6.4 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
6.5 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data, after you supplied appropriate evidence of your identity (this will require you to log in). The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
6.6You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
6.7 In some circumstances, you have the right to the erasure of your personal data without undue delay and which we will endeavor to do within 30 days of your request. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consentbased processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary for exercising the right of freedom of expression and information and for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6.8 In some circumstances, you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.9 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
6.10 You have the right to object to our processing of your personal data for direct marketing purposes. If you make such an objection, we will cease to process your personal data for this purpose.
6.11 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
6.12 To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.13 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
6.13 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.14 You may exercise any of your rights in relation to your personal data by contacting us by telephone or email.
Third party websites
7.1 Our website includes hyperlinks to, and details of, third party websites.
7.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
Personal data of children
8.1 Our website and services are targeted at persons over the age of 18.
8.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
9.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
Acting as a data processor
10.1 Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12 Cookies that we use
13.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-deletemanage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
13.2 Blocking all cookies will have a negative impact upon the usability of many websites. 13.3 If you block cookies, you will not be able to use all the features on our website.
14.1 This website is owned and operated by SNT Ltd.
14.2 We are registered in England and Wales under registration number XXXXX, and our registered office is at 121 Earlsgate Winterton Scunthorpe DN15 9ST
14.3 Our principal place of business is at 121 Earlsgate Winterton Scunthorpe DN15 9ST
14.4 You can contact us:
(a) by post, using the postal address given above;
(b) by telephone, on ++44 7908 912485; or
(c) by email, using email@example.com