Derwent Stepping Stones understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
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. Details of the Cookies used by Our Site are set out in section 13, below;
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;
means all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
means Derwent Stepping Stones, a limited company registered by guarantee in England under company number 02826849 and as a charity, number 1024544 whose registered and trading address is address is Derwent Stepping Stones, St Marks Rd, Derby DE21 6AH.
“Anonymised data” Anonymisation is the removal of information that could lead to an individual being identified, either on the basis of the removed information or this combined with other information held by the Charity.
2. Information About Us
2.1 Our Site is operated by Derwent Stepping Stones, a limited company registered by guarantee in England under company number 02826849 and as a charity, number 1024544 whose registered and trading address is address is Derwent Stepping Stones,.
2.2 Our Data Protection Officer is Jo Allen, and can be contacted by email at [email protected], by telephone on 01332 372245, or by post at St Marks Rd, Derby DE21 6AH
2.4 We are regulated by Companies House, the Charities Commission and Ofsted
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights to opt out of automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
5.2 contact information such as email addresses and telephone numbers;
5.3 IP address;
5.4 web browser type and version;
5.5 operating system;
5.6 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary considering the reason(s) for which it was first collected. We will always comply with Our obligations and safeguard your rights under the GDPR. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Providing and managing your access to Our Site;
6.2.2 Personalising and tailoring your experience on Our Site;
6.2.3 Personalising and tailoring Our products and services for you;
6.2.4 Replying to emails from you;
6.2.5 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking on the unsubscribe link at the bottom of emails sent to you.
6.2.6 Market research;
6.2.7 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.
6.3 With your expressed permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email or telephone or text message or post with information, news and offers on Our products and 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.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods as laid out in Our Data Retention Policy.
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
7.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.4 Steps We take to secure and protect your data include:
7.4.1 Implementation of HTTPS and redirect all HTTP traffic to HTTPS.
7.4.2 Use an updated version of TLS.
8. Do We Share Your Data?
8.1 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 data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such anonymised statistical data with third parties such as prospective investors, grant giving bodies, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9. How Can You Control Your Data?
9.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details.\
9.2 You may also wish to sign up to one or more of the preference services operating in the UK: 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 receiving.
10. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at [email protected]. or using the contact details below in section 14.
11.2 All Cookies used by and on Our Site are used in accordance with current Cookie Law.
11.3 You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
11.4 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 11.8, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
11.5 Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products/services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
11.6 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
11.7 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently.
11.8 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
12. Contacting Us