Privacy Policy

Version 1.5

Last revised on: 1 July 2021

Introduction

Welcome to Goodsted’s privacy policy!

We at Goodsted (Goodsted Community LTD, “we”, “us”, “our”) are committed to protecting the privacy of all personal data collected in the course of our business, including via this website and via our online software services, related applications, products or tools (together the “Goodsted Platform” or “Subscription Service”). This privacy policy will inform you as to how we look after your personal data when you visit our website and other applications linked to this Privacy Policy such as the Goodsted Platform (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This Policy applies to users of our Subscription Service as well as their individual members and employees. It also applies to other site visitors such as prospective clients and subscribers to our web-based resources and informational materials.

If the version of the Goodsted Platform you access is managed by an Organisation Member, the data you provide is shared with this Organisation. You can find their privacy policy linked within the Platform in the ‘More’ section of your navigational menu.

Important information and who we are

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website and our Platform, including any data you may provide when you create an account, join a group, team or community and/or sign up to our newsletter.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

2.1 Controller

Goodsted Community LTD is the controller and is responsible for your personal data. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

2.2 Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity :Goodsted Community LTD

Email address :hello@goodsted.com

Postal address :Impact Brixton, Pop Brixton, 49 Brixton Station Rd, Brixton, London SW9 8PQ.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would,however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

2.3 Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review and have the right to change this policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on our website and you should check back frequently to see any updates or changes to our policy.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us

2.4 Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. We are not responsible for the content and practices of these websites and please note in particular that we have no control over any use of cookies on these websites.

We will always comply with relevant Data Protection Legislation (including the Data ProtectionAct 2018 (“DPA”) and the General Data Protection Regulation (“GDPR”) as applicable) when dealing with your personal data. Further details on the DPA and GDPR can be found at the Information Commissioner’s Office website (www.ico.gov.uk).

2.5 Age restrictions

You must be 18 years of age or older to register an Initiative or Organisation and 16 years old to visit our Website and register to the Platform. We do not knowingly collect personal information from individuals under 16 years of age. If you are under that age limit, then please do not use Goodsted or provide any personal information to us. If you are under 18 years of age, then you will be required to have consent of your parent or guardian to access the Website and we will only process the basic information which we require from you so that you can use our Platform.

If you are a parent or legal guardian of a child under the applicable age limit or accessing our services without consent, and you become aware that your child has provided his/her personal information to us, please contact us at hello@goodsted.com. If we learn that we have collected personal information of an individual under the age of 16, then we will take all reasonable steps to delete that information from our systems, and if required, delete the relevant member account.

GDPR Compliance

We only ever use your information in line with applicable data protection laws – in particular, the EU General Data Protection Regulation (GDPR). In short, this means we only use it where we have a legal basis to do so. Under GDPR, these are the general legal bases for which we process your personal information, as detailed in the section below.

Consent – you have given us consent to process your personal information for a specific purpose that we have told you about.

Performance of our contract – processing your personal information is necessary for a contract you have with us, or because we have asked you to take specific steps before entering into that contract.

Legitimate interests – processing your personal information is necessary for our legitimate interests or those of a third party, provided those interests are not outweighed by your rights and interests (including where processing is required to comply with or enforce a legal obligation, or to exercise or defend our legal rights).

What data we collect

Personal data or “Personal Information” means any information about an individual from which that person can be identified. It does not include data of an anonymous or aggregate nature, where a specific individual cannot be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, last name, and title.
Contact Data includes your address (your borough and city of residence) and email address.
Transaction Data includes details about your engagement on the Goodsted platform, including volunteering your time, skills or other in-kind resources.
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Usage Data includes information about how you use our Website.
Profile Data includes your username and password, your preferences, feedback and survey responses.
Financial Data includes bank account and payment card details

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or Platform feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and geneticand biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with Services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How we collect your data

We use different methods to collect data from and about you including through:

Direct interaction: You may give us your Identity, Financial and Contact Data by joining the Goodsted Platform or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

create and manage your user account
give us feedback or contact us
engage in an opportunity
join a group and/or a community
pay for our Subscription Services

Automated technologies or interactions: As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Cookies. Cookies amongst other things, help us to improve your experience on the Platform and to ensure that it performs as you expect it to. Cookies are text files containing small amounts of information, which are downloaded to your computer or mobile device by websites that you visit. They can improve your experience of using a website, for example, by remembering your preference settings and tracking your use of a website so that it can be improved to meet your needs.

Websites must get consent to send cookies to your computer or mobile device unless the cookies are strictly necessary to provide services to you. We ask users of our website if they would like to accept cookies when they visit our website. You have the right to refuse cookies. Although, please do remember that if you do not consent to our functionality cookies, parts of our website will not work. Unless the cookie is strictly necessary, you can withdraw your consent to our cookies at any time even if you have previously consented. You can also set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.

Why we collect your data

We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances: (i) where we need to perform the contract we are about to enter into or have entered into with you; (ii) where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; (iii) where we need to comply with a legal obligation.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

1 - To process and deliver our services including:

(a) Manage payments

(b) Collect and recover money due to us (e.g. for members who have subscribed to premium membership for their community page or team page)

Type of data:

(i) Identity

(ii) Contact

(iii) Transaction

Lawful basis for processing including basis of legitimate interest:

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

2 - To manage our relationship with you, which will include notifying you about changes to our data retention and protection policy:

Type of data

(i) Identity

(ii) Contact

Lawful basis for processing including basis of legitimate interest:
(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

3 - To administer and protect our business (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data

(i) Identity

(ii) Contact

(iii) Technical

Lawful basis for processing including basis of legitimate interest:

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

4 - To use data analytics to improve our business, products/services, customer relationships and experiences

Type of data

(i) Technical

(ii) Usage

Lawful basis for processing including basis of legitimate interest:

(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, incompliance with the above rules, where this is required or permitted by law.

When will we share your data

We may share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We may also share your personal data with external third parties such as: service providers who provide IT and system administration services to us; professional advisers, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services; and HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

International transfers

The Data that we collect from you may be transferred to, and stored at, a destination outside the UK. It may also be processed by staff operating outside the UK who work for us or for one of our suppliers. We will always ensure that appropriate safeguards are in place to ensure the privacy of your Data in accordance with the standards set out in relevant Data Protection Legislation.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, volunteers, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

In the event that, despite all the precautions, a data leak were to occur and adversely impact you, we will notify you of such an eventuality as soon as possible (within 72 hours). If required, we will also notify the respective supervisory authorities of such an eventuality as soon as possible (within 72 hours).

How long we keep data for

We will at all times ensure that the minimum amount of personal data is kept, and for no longer than necessary, for us to meet our document retention objectives and data protection obligations.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Data that you share with us by signing up to our website (Identity, Contact, Financial and Transaction data) will be kept by us until you or we close your account or you otherwise request that we delete your data.

We will then remove your data by deleting your Identity, Contact and Financial data, save for your area (this may be your borough, town or county). We shall anonymise the rest of your data (largely Transaction data) in order to learn about the success of our projects. If you would prefer for us to delete all your data rather than anonymise it please let us know. We will be happy to do so provided you get in touch before we anonymise the data. Please note that, as described above, anonymised data is not personal data.

We shall endeavour to delete or anonymise your Identity, Contact, Financial and Transaction data within 48 hours, but in circumstances of unprecedented occupation we may require up to one week to delete or anonymise your data.

In general we will anonymise Technical and Usage data received from our Website within 24 hours. We may retain your non-anonymised data for more than 24 hours should we be required to do so in order to comply with our legal obligations. Our legal obligations as referred to in this Policy are our statutory obligations and obligations arising from any other binding law.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of these rights, please contact us. In particular, you have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required; You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you; We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond; We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Notice to California Residents

If you are a California resident, you may be entitled to additional rights over your personal information, as detailed in this section. In compliance with the California Civil Code Section 1798.83, residents of California are hereby notified that the Goodsted Platform, the services and the appertaining personal data are safeguarded by us. Our users can obtain certain information about the personal data we may have access to, including disclosure thereof with third parties for direct marketing purposes (e.g. names and addresses of those third parties, types of services or products marketed thereby). If you wish to request a copy of your information disclosure, please contact us at hello@goodsted.com.

California Online Privacy Protection Act

In compliance with CalOPPA, we have hereby posted this Policy, indicating the personal data being collected and the manner in which it may be disclosed and with whom. Accordingly, our users may visit our website using anonymous browsing, this Policy linked in our home page, with the link including the word ‘Privacy’ or similar. We also comply with Policy change notification to our users, and provide mechanisms that allow our users to manage their personal data and personal information.

Third Party Service Providers

Goodsted may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

As a condition of permitting Service Providers to process your Personal Data, we will enter into a written agreement with each Provider containing data protection obligations at least as protective as the technical and organizational measures Goodsted has put into place to protect your Personal Data from accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access.

These Service Providers are listed below, with a description of the service and the location where data is hosted. This list may be updated by Goosted from time to time:

Digital Ocean. Developer cloud; main hosting and storage servers (EEA)
Github. Code repository (USA)
Amazon Web Services, Inc. Cloud service provider; domain service (USA)
Google LLC, Cloud service provider (USA)
Intercom, Inc. Cloud-based customer support services (USA)
Stripe, Inc. Online payment transactions (USA)

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

Hotjar is a technology service that helps us better understand our users’ needs and experiences (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.). This enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

Pendo is a technology service that helps us better understand our product experience and digital adoption. It enables us to deliver a digital experience you will love, building and maintaining our service with user feedback. Pendo uses cookies and other technologies to collect data on our users’ behaviour and their devices. For more information on the privacy practice of Pendo, please visit Pendo’s Privacy Policy.

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page.