Privacy policy The AIRE Centre Privacy Policy Last Updated: July 2018 1. APPLICABILITY OF PRIVACY POLICY This is the Privacy Policy of Advice on Individual Rights in Europe (also known as The AIRE Centre), with office address at Room 505, Institute of Advanced Legal Studies, Charles Clore House, 17 Russell Square, London WC1B 5DR ("us", "we" or "our"). This Privacy Policy applies to our processing of personal data in relation to the use of our website. This Privacy Policy explains how we collect, use and protect your personal data. Respecting and protecting your privacy and your personal data is very important to us. Your personal data will be held by us in accordance with the data protection laws of the United Kingdom. For the purposes of data protection laws in the United Kingdom, the controller is The AIRE Centre. If you have any questions in relation to this Privacy Policy, please contact us at: Address: Attn: Business & Finance Manager, The AIRE Centre, Room 505, Institute of Advanced Legal Studies, Charles Clore House, 17 Russell Square, London WC1B 5DR Telephone: +44 20 7831 4276 Email: [email protected] Please read this Privacy Policy to understand how we will collect and use your personal data and the rights you have in relation to your personal data. This Privacy Policy was last updated on the date above and may vary from time to time so please check it regularly. By visiting our website and using our products and services, you acknowledge the terms of this Privacy Policy and the use and disclosure of your personal data as set out in this Privacy Policy. 2. HOW WE COLLECT YOUR PERSONAL DATA When you visit our website, we may collect the following information from you directly and/or automatically: information you provide to us if you contact us, for example to report a problem with our website or raise a query or comment; and details of visits made to our website such as the volume of traffic received, logs (including, the internet protocol (IP) address and location of the device connecting to the online services and other identifiers about the device and the nature of the visit) and the resources accessed. 3. WHY WE COLLECT YOUR PERSONAL DATA We use your personal data for the following non-exhaustive list of purposes: administering and managing our website and systems and applications; making improvements to our website; and complying with our legal, regulatory and professional obligations. 4. WHO DO WE SHARE YOUR DATA WITH? We may share your personal data with the following categories of recipients: Regulatory bodies We may disclose your personal data: to the Charity Commission; in response to an enquiry from a government agency; to data protection regulatory authorities (including the UK Information Commissioner's Office); and to other regulatory authorities with jurisdiction over our activities. Service providers We may disclose your personal data to third party service providers who require access to such information for the purpose of providing specific services to us. These third parties will generally only be able to access your data in order to provide us with their services and will not be able to use it for their own purposes. Professional advisors and Auditors We may disclose your personal data to professional advisors (such as legal advisors and accountants) or auditors for the purpose of providing professional services to us. Replacement providers In the event that we sell or buy any business assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. If AIRE or substantially all of its assets are acquired by a third party, personal data held by us about our clients will be one of the transferred assets. 5. WHAT ARE MY RIGHTS? You have various rights in relation to the data which we hold about you. We have described these below. To get in touch with us about any of these rights, please contact us at: Address: Attn: Business & Finance Manager, The AIRE Centre, Room 505, Institute of Advanced Legal Studies, Charles Clore House, 17 Russell Square, London WC1B 5DR Telephone: +44 20 7831 4276 Email: [email protected] We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise. The GDPR gives you the following rights in relation to your personal data: Right to object This right enables you to object to us processing your personal data where we do so for one of the following reasons: because it is in our legitimate interests to do so (for further information please see section 10 below); to enable us to perform a task in the public interest or exercise official authority; to send you direct marketing materials; or for scientific, historical, research, or statistical purposes. Right to withdraw consent Where we have obtained your consent to process your personal data for certain activities, you may withdraw this consent at any time and we will cease to use your data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition. Data Subject Access Requests You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so. Right to erasure You have the right to request that we "erase" your personal data in certain circumstances. Normally, this right exists where: The data are no longer necessary; You have withdrawn your consent to us using your data, and there is no other valid reason for us to continue; The data has been processed unlawfully; It is necessary for the data to be erased in order for us to comply with our obligations under law; or You object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing. We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so. When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data. Right to restrict processing You have the right to request that we restrict our processing of your personal data in certain circumstances, for example if you dispute the accuracy of the personal data that we hold about you or you object to our processing of your personal data for our legitimate interests. If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data. Right to rectification You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision. Right of data portability If you wish, you have the right to transfer your personal data between service providers. In effect, this means that you are able to transfer the details we hold on you to another third party. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the data for you. Right to complain You have the right to lodge a complaint with our regulator, who is the Information Commissioner's Office in the UK. You can contact them in the following ways: Phone: 0303 123 1113 Email: [email protected] Live chat Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF 6. COOKIES Cookies are small data files sent by a website to your computer that are stored on your hard drive when you visit certain online pages of our website. Your continued use of our website is your acceptance of our continued use of cookies on our website. Please see our Cookie Policy for further details. 7. SECURITY We will take all reasonable precautions necessary to protect your personal data from misuse, interference and loss; and unauthorised access, modification or disclosure. This includes, for example, the protection of passwords using industry standard encryption, measures to preserve system security and prevent unauthorised access and back-up systems to prevent accidental or malicious loss of data. We may use third party data storage providers to store personal data electronically. We take reasonable steps to ensure this information is held as securely as information stored on our own equipment. Unfortunately, there is always risk involved in sending information through any channel over the internet. You send information over the internet entirely at your own risk. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted over the internet and we do not warrant the security of any information, including personal data, which you transmit to us over the internet. 8. INTERNATIONAL TRANSFERS OF DATA The data that we collect from you may be transferred to, and stored at, destinations both within and outside the European Economic Area (EEA). As discussed above, we may disclose your personal data to our service providers, who may be located outside the EEA. We want to make sure that your personal data is stored and transferred in a way which is secure. We will therefore only transfer data outside of the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data. For example, this could be: By way of a data transfer agreement with a third party, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by controllers in the EEA to controllers and processors in jurisdictions without adequate data protection laws; or By transferring your data to an entity which has signed up to the EU-U.S. Privacy Shield Framework for the transfer of personal data from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or By transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or Where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer your data to a benefits provider based outside the EEA); or Where you have explicitly consented to the data transfer. Where we transfer your personal data outside the EEA and where the country or territory in question does not maintain adequate data protection standards, we will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. 9. HOW LONG WILL WE KEEP YOUR PERSONAL DATA? We will not keep your personal data for longer than is necessary for the purposes for which we have collected it, unless we believe that the law or other regulation requires us to keep it (for example, because of a request by a tax authority or in connection with any anticipated litigation) or if we require it to enforce our agreements. In general, we will retain your personal data for as long as we provide services to you and, following that period, we will only retain your personal data for as long as is reasonably necessary in the circumstances. When it is no longer necessary to retain your personal data, we will delete the personal data that we hold about you from our systems. While we will endeavour to permanently erase your personal data once it reaches the end of its retention period, some of your personal data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists in the electronic ether, our employees will not have any access to it or use it again. 10. LEGAL CONDITIONS FOR USING YOUR PERSONAL DATA There are a number of different ways that we are lawfully able to process your personal data. We have set these out below. Where using your data is in our legitimate interests We are allowed to use your personal data where it is in our interests to do so, and those interests aren't outweighed by any potential prejudice to you. We believe that our use of your personal data is within a number of our legitimate interests, including but not limited to: To enable us to provide legal advice services; To help us satisfy our legal obligations; To help us understand our website users better and provide better, more relevant services to them; and To help us keep our systems and physical premises secure and prevent unauthorised access or cyber attacks. We don't think that any of the activities set out in this privacy policy will prejudice you in any way. However, you do have the right to object to us processing your personal data on this basis. We have set out details regarding how you can go about doing this in section 5 above. Where you give us your consent to use your personal data We are allowed to use your data where you have specifically consented. In order for your consent to be valid: It has to be given freely, without us putting you under any type of pressure; You have to know what you are consenting to – so we'll make sure we give you enough information; You should only be asked to consent to one thing at a time – we therefore avoid "bundling" consents together so that you don't know exactly what you're agreeing to; and You need to take positive and affirmative action in giving us your consent – we're likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion. As part of our relationship with you, we may ask you for specific consents to allow us to use your data in certain ways. If we require your consent, we will provide you with sufficient information so that you can decide whether or not you wish to consent. You have the right to withdraw your consent at any time. We have set out details regarding how you can go about this in section 5 above. Where processing is necessary for us to carry out our legal obligations As well as our obligations to you under any contract, we also have other legal obligations that we need to comply with and we are allowed to use your personal data when we need to in order to comply with those other legal obligations. Your data may also be available to our website provider to enable us and them to deliver their service to us, carry out analysis and research on demographics, interests and behaviour of our users and supporters to help us gain a better understanding of them to enable us to improve our services. This may include connecting data we receive from you on the website to data available from other sources. Your personally identifiable data will only be used where it is necessary for the analysis required, and where your interests for privacy are not deemed to outweigh their legitimate interests in developing new services for us. In the case of this activity the following will apply: Your data will be made available to our website provider The data that may be available to them include any of the data we collect as described in this privacy policy. Our website provider will not transfer your data to any other third party, or transfer your data outside of the EEA. They will store your data for a maximum of 7 years. This processing does not affect your rights as detailed in this privacy policy Manage Cookie Preferences