Privacy Policy
We take privacy seriously, which is why we have taken measures to protect the privacy of members and visitors to our website. Questions, comments and requests regarding this Privacy Policy are welcomed and should be sent to accounts@greatergovanhill.com.
When you use Greater Govanhill CIC’s website you should be aware that Greater Govanhill CIC may collect certain information about you.
Greater Govanhill CIC collects this information so that we can provide our products and services, run our business, contact you and comply with the law.
1. Privacy Policy for Greater Govanhill CICI
1.1 Greater Govanhill CIC is a community interest company registered in Scotland with company number SC656194 and registered at 82 Bowman Street, Glasgow, G42 8LF.
1.2 This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our website and giving us information you acknowledge the practices described in this policy. If you do not agree to us collecting and using the information about you then you must not use our website.
1.3 Our website may, from time to time, contain links to and from the websites of our partners and affiliates, for example third party payment processors. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
1.4 We reserve the right to modify this Privacy Policy at any time and, where material changes have been made, you will be notified of changes we make to this Privacy Policy.
2. Information we may collect from you
2.1 We may collect and process the following information in accordance with applicable data protection laws:
(a) the email address provided by you if you register or post content, to validate such registration or content and for password reset purposes.
(b) information provided via online form submission such as:
an enquiry;
a report of a problem with our website; or
in response to a communication from us.
Through these forms we may be provided with certain personal data such as your name, email address and information contained in the correspondence (which could tell us something about the individual’s preferences).
The individual contacting us is in control of the personal data and other information that they share with us. We need this information to be able to respond to the enquiry and to administer our website.
(c) details of registration, membership and subscription transactions you carry out in relation to our website, including but not limited to name, order information, billing information, address, type of subscription, hashed payment details, including whether payments have been accepted or declined. We need this information to be able to provide our products and services to you.
(d) information provided when individuals visit our website. We capture access data such as IP address, browser type and version, time zone setting, operating system and platform, date and time of the access, requests made,. This information does not allow us to identify you. We may also capture other information about visits to our website such as site usage and traffic patterns.
Whereas we may be able to identify an individual device and therefore an individual from this information, the purpose of collecting information is to administer, maintain and improve our website and not to analyse individual visits to our website (please see the “purposes for processing” section below for further details).
(e) Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if you were visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
2.2 Where you provide us with personal data about other people, you warrant that you have the authority to pass this information to us. Please note this does not apply to information of journalistic interest.
2.3 We are required to comply with certain legal and regulatory requirements, and may process your personal data for compliance with such legal or regulatory obligations, to which we or regulators or law enforcement agencies are subject. In this eventuality we may seek independent legal advice to determine the lawfulness of any data access request.
2.4 If any of your personal details change during your use of our website, you are responsible for updating them by accessing the relevant section of the our website or by contacting accounts@greatergovanhill.com
3. Purposes of processing
3.1 Any personal data we process will be used in accordance with applicable data protection laws. We describe below our purposes for processing personal data.
3.2 We may use information you give us or that we collect from you:
(a) to provide our products and services, administer user accounts and user content and run our organisation;
(i) we have a legitimate interest to process the personal data of our users in order to provide products and services, administer user accounts and run our organisation;
(b) to inform individuals about promotions and our products and services:
(i) we may use personal data to inform individuals of information, promotions, suggestions, recommendations, products and services that may be of interest where they are similar to those that you have already purchased or enquired about such as membership and events (unless you opt-out), we are legally permitted to do so or where an individual has consented to receiving direct marketing from us.
Individuals may be contacted by post, email, telephone or such other means as we regard as appropriate and as legally permitted;
(ii) we have a legitimate interest to process the personal data of our users for direct marketing purposes to provide our products and services and to run our business and rely on consent from the user as a basis for direct marketing where we are legally required to do so; and
(iii) if you are an existing user, we will only contact you with information about products and services similar to those which were the subject of a previous transaction with you.
(c) to communicate with you:
(i) we have a legitimate interest to process this personal data in order to respond to enquiries, requests, complaints or comments that users submit to us;
(d) to administer, maintain and improve our website:
(i) we use “cookies” to monitor site user traffic patterns and site usage. This helps us to understand how our users and potential users use our website so that we can develop and improve the design, layout and functionality of the sites.
(ii) to process the personal data of our users in order to administer, maintain and improve our website;
(e) to notify you about changes to our service. This processing is necessary for the performance of our contract with you;
(f) for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. We have a legitimate interest in processing the personal data of our users for our internal operations;
(g) to allow you to participate in interactive features of our service. This processing is necessary for the performance of our contract with you;
(h) as part of our efforts to keep our website safe and secure. We have a legitimate interest in processing the personal data of our users to keep our website safe and secure; and
(i) to comply with any legal or regulatory obligations to which we or regulators or law enforcement agencies are subject. This processing is necessary for compliance with a legal obligation to which we, our users or the regulator/law enforcement agency are subject.
3.3 If you have any questions about how we use your data please contact us at accounts@greatergovanhill.com.
4. Disclosure of your information
4.1 We maintain a principle not to disclose your personal data to third parties without your consent. However, we may share your personal data if we are under a duty to or permitted to disclose it in order to comply with any legal or regulatory obligations, or in order to enforce or apply our website T&Cs and other agreements; or to protect the rights, property, or safety of Greater Govanhill CIC, our users, or others’ personal data. In these circumstances we will notify you in advance wherever possible.
5. Where we store your data
5.1 You acknowledge that by posting or uploading any content on our website, including any articles submitted for publication on our website, that such content and articles will be viewable and available worldwide by other users who view our website.
5.2 If we or our service providers transfer any personal data out of the European Economic Area (EEA), it will only be done with the relevant protection (stated under UK law) being in place.
6. Retention of your data
We take appropriate measures to ensure that any personal data is kept secure. We will store your personal data for the duration of your use of our website. If you delete your account, we will continue to store your personal data for as long as is required by legal, regulatory, financial and business requirements. We also keep a record of correspondence for as long as is required by legal, regulatory, financial and business requirements. We will delete such personal data and correspondence once it is no longer required.
7. Access to information and Your rights
7.1 As a result of us collecting and processing your information, you have the following legal rights:
(a) to access personal data held about you;
(b) to request us to make any changes to your personal data if it is inaccurate or incomplete;
(c) to request your personal data is erased where we do not have a compelling reason to continue to process such data in certain circumstances;
(d) to receive your personal data provided to us as a data controller in a usable way in certain circumstances;
(e) to object to, or restrict, our processing of your personal data in certain circumstances;
(f) to object to, and not be subject to a decision which is based solely on, automated processing (including profiling), which produces legal effects or could significantly affect you;
(g) where our processing of your personal data is based on your consent you have the right to withdraw consent at any time by contacting us; and
(h) to lodge a complaint with a data protection supervisory authority. The supervisory authority in the UK is the Information Commissioner’s Office.
7.2 To exercise any of your rights as set out above, please contact us at accounts@greatergovanhill.com
beabee
We use beabee (beabee.io) by CORRECTIV - Recherchen für die Gesellschaft gemeinnützige GmbH. Huyssenallee 11, 45128 Essen, for the administration of our donor and user data as well as the targeted integration of our community via digital communication channels and the creation of user profiles. For this purpose, beabee stores data such as email address, name, payment data such as payment method and date of membership conclusion. All data is stored in Germany.
Sendgrid
We use Sendgrid, a tool from Twilio Inc. to send automatic emails. Twilio is based in the USA. To provide the SendGrid services, Twilio uses data centres from Zayo and Centurylink in the USA. Therefore, there is a transfer of data to third parties in a non-secure third country. More information about Twilio's privacy policy can be found here:
https://www.twilio.com/legal/data-protection-addendum https://www.twilio.com/gdpr https://www.twilio.com/legal/security-overview
Stripe
Source: https://opr.vc/docs/payment/stripe/
We offer the option of processing the payment transaction via the payment service provider Stripe, ℅ Legal Process, 510,Townsend St., San Francisco, CA 94103 (Stripe). This is in line with our legitimate interest in offering an efficient and secure payment method (Art. 6 para. 1 lit. f DSGVO). In this context, we share the following data with Stripe to the extent necessary for the performance of the contract (Art. 6 para. 1 lit b. DSGVO).
Name of the cardholder E-mail address Customer number Order number Bank details Credit card details Period of validity of the credit card Credit card verification number (CVC) Date and time of transaction Transaction amount Name of the provider Place
The processing of the data provided under this section is not required by law or contract. We cannot process a payment through Stripe without the submission of your personal data. Stripe has a dual role as a controller and processor in data processing activities. As a controller, Stripe uses your submitted data to comply with regulatory obligations. This corresponds to Stripe's legitimate interest (pursuant to Art. 6 para. 1 lit. f DSGVO) and serves the performance of the contract (pursuant to Art. 6 para. 1 lit. b DSGVO). We have no influence on this process.
Stripe acts as a processor in order to be able to complete transactions within the payment networks. Within the scope of the order processing relationship, Stripe acts exclusively according to our instructions and has been contractually obligated within the meaning of Art. 28 DSGVO to comply with the provisions of data protection law.
Stripe has implemented compliance measures for international data transfers. These apply to all global activities where Stripe processes personal data of individuals in the EU. These measures are based on the EU Standard Contractual Clauses (SCCs).
For more information on opt-out and redress options against Stripe, please visit: https://stripe.com/privacy-center/legal
Your data will be stored by us until the completion of the payment processing. This also includes the period required for processing refunds, claims management and fraud prevention. [A statutory retention period of [X] years applies to us in accordance with [§ 147 AO / § 257 HGB] for the following documents: [ ]].