Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller's possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the "GDPR") and other data protection laws (referred to in this document as "Data Protection Legislation").

As the owner of eCLIPS, Adviza Partnership (Adviza) is the data controller. This means it decides how your personal data is processed and for what purposes. Adviza is a company limited by guarantee incorporated and registered in England and Wales with company number 06534168 and our registered office is 11th Floor Ocean House, The Ring, Bracknell, RG12 1AX. We are a registered charity with the Charity Commission in England and Wales with registration number 1132201.

Our Data Protection Officer can be contacted by email at dataprotection@adviza.org.uk or by post to 11th Floor Ocean House, The Ring, Bracknell, RG12 1AX.

Adviza complies with its obligations under Data Protection Legislation by keeping personal data up to date; by only processing data for the purpose for which it was collected; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data. All personal data is kept on central IT systems and is not stored or transported on portable electronic devices.

We use your personal data for the following purposes:

• To enable us to provide goods and services for the benefit of the public as specified in our governing document
• To send you notifications which you have specifically requested
• Where you have specifically given us your consent to do so, to inform you of news, events, activities and services, and to survey your views on matters relevant to our services including sending to you newsletters and other marketing communications relating to our business or the businesses of carefully-selected third parties
• To deal with enquiries and complaints made by you about our goods or services
• To administer our online services and improve your browsing experience by personalising online services
• To keep our services secure and prevent fraud
• To maintain our own accounts and records
• Further details of how we process personal data are provided in the Appendices to this notice for different categories of data subject.

Details of the legal basis for process personal data are provided in the Appendices to this notice for different categories of data subject.

Details of the kinds of personal data we collect are provided in the Appendices to this notice for different categories of data subject.

We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

We will store all the personal information you provide on our secure (password- and firewall- protected) servers, all of which are provided by accredited third party providers, who are our data processors and with whom we have legal agreements about data processing (see below). All electronic payments you make to, or receive from, us will be encrypted through PayPal. We do not store any credit or debit card details and hold a current Payment Card Industry Data Security Standard (PCI DSS) Certificate of Compliance. You can find out more information about PCI DSS at https://www.pcisecuritystandards.org/pci_security/

You are responsible for keeping your password and user details confidential. We will never ask you to disclose your password. Although we use appropriate security measures, data transmission over the internet is never completely secure, and we cannot guarantee the security of data sent over the internet.

Where we have obtained your personal data from a third party (other than in our capacity as data processor) we will tell you who we have obtained it from and what personal data has been shared with us.

We may disclose information about you to any of our employees, officers, agents, suppliers or subcontractors insofar as is reasonably necessary for the purposes as set out in this Privacy Notice.

In addition, we may disclose your personal information to third parties:

• to the extent that we are required to do so by law;
• in connection with any legal proceedings or prospective legal proceedings;
• in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
• to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
• to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

Except as provided in this Privacy Notice, we will not provide your information to third parties. The information you provide will not be transferred to countries outside the European Economic Area (EEA).

Data processors are third parties who provide elements of our services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct. The Appendices to this privacy notice specify the main data processors we engage for different categories of data subject. In addition, our main IT servers are hosted by Connect Systems Ltd, who are a data processor on our behalf.

We keep data in accordance with the Data Protection Legislation and only for as long as is necessary including to comply with the law, regulatory and contractual requirements and record keeping requirements of HMRC and other regulators. Specific details are available in our Document Retention Policy (available on request) and the Appendices to this privacy notice include the main retention period we follow for different categories of personal data and data subject.

Under Data Protection Legislation, you have rights as an individual which you can exercise in relation to the information we hold about you. Unless otherwise specified in law, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data Adviza holds about you, provided you supply appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address). We may withhold such personal information to the extent permitted by law
• The right to request that we correct any personal data if it is found to be inaccurate or out of date
• The right to request your personal data is erased where it is no longer necessary or required for Adviza to retain such data. This right does not apply where we have a legal obligation to retain your data
• The right to withdraw your consent to the processing of your data at any time (if we are processing on the basis of your consent)
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability). This right only applies where we are processing your personal data based on consent or for the performance of a contract with you and in either case we are processing the data by automated means
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing.
• The right to object to the processing of personal data. This right only applies where we are processing your personal data based on legitimate interests.
• The right to lodge a complaint with the Information Commissioners Office.

You can read more about these rights here https://ico.org.uk/concerns/

If we wish to use your personal data for a new purpose, not covered by this Privacy Notice, then we will publish a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

This privacy notice does not cover the links within our website linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

Adviza tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Adviza's collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.

If you want to request information about our Privacy Notice or exercise all relevant rights, queries or complaints please in the first instance contact our Data Protection Officer, either by email at dataprotection@adviza.org.uk or by post to Data Protection Officer, Adviza Partnership, 11th Floor Ocean House, The Ring, Bracknell, RG12, UK.

You can contact the Information Commissioners Office on 0303 123 1113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire. SK9 5AF.

We keep our privacy notice under regular review. This privacy notice was last updated in May 2018.

We may collect, store and use the following kinds of personal information:

• information about your computer and about your visits to and use of our online services (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and online services navigation);
• information relating to any transactions carried out between you and us on or in relation to these online services, including information relating to any purchases you make of our goods or services;
• information that you provide to us for the purpose of registering with us (including your name, email address and telephone number);
• information that you provide to us for the purpose of contacting us through the contact form (including your name, email address and telephone number); and
• information that you provide to us for the purpose of subscribing to our online services, email notifications and/or newsletters (including your email address).

Analytics

When someone visits our website, we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it. Google's Privacy Notice is available at: https://policies.google.com/privacy?hl=en-GB

Use of cookies by Adviza

You can read more about how we use cookies in our Cookie Policy.

Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third party cookies. Blocking all cookies will, however, have a negative impact upon the usability of many online services, including this one.

Where personal data is collected in the course of fulfilling our contractual and legal obligations to you or when you have asked us to provide services to you it is processed to fulfil our contractual obligations to you, to comply with other legal obligations or in our and your legitimate interests (e.g. to provide you with information and services requested by, or promised to, you, to ensure continuity of services and manage repeat business effectively and/or to defend any legal claims). The other considerations set out elsewhere in this policy also apply.

Your explicit consent is required so that we can send you newsletters and other marketing communications relating to our business or the businesses of carefully-selected third parties (see Appendix B below). You can withdraw your consent at any time by clicking the unsubscribe link in the footer of any email you receive from us, or by sending us a text message to opt out following the instructions we provide in our texts, or by contacting us at marketing@adviza.org.uk.

We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted by us for such purposes. However, we will retain your details on a suppression list to help ensure that we do not continue to contact you.

The main data processors engaged in processing personal data on our behalf for this category of data subject are:

PayPal

All our online financial transactions are handled through our payment services provider, PayPal. We will share information with PayPal only to the extent necessary for the purposes of processing payments you make via our online services, refunding such payments and dealing with complaints and queries relating to such payments and refunds. PayPal may also send you cookies. You can review the PayPal Privacy Notice at www.paypal.com

We do not store any credit or debit card details and hold a current Payment Card Industry Data Security Standard (PCI DSS) Certificate of Compliance. You can find out more information about PCI DSS at https://www.pcisecuritystandards.org/pci_security/

Website developers

We work with third party website developers who build, host and maintain our eCLIPS website. As such, they process personal data on our behalf and only in accordance with this Privacy Notice.

Security and performance

Adviza uses third-party services to help maintain the security and performance of our websites. To deliver this service they process the IP addresses of visitors to eCLIPS.

We may collect, store and use the following kinds of personal information:

• information about your computer and about your visits to and use of our online services (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and online services navigation);
• information that you provide to us for the purpose of registering with us (including your name, email address and telephone number);
• information that you provide to us for the purpose of contacting us, e.g. through a contact form (including your name, email address and telephone number); and
• information that you provide to us for the purpose of subscribing to our information services and/or newsletters (including your email address).

We provide people with information about special features of our website, our services and any other information we think may be of interest to them. We process personal data for these purposes only with your explicit, specific, informed and freely given consent.

If you agree to us providing you with marketing information, you can always withdraw your consent at any time by clicking the unsubscribe link in the footer of any email you receive from us or by contacting us at marketing@adviza.org.uk.

We will not use your personal information for marketing purposes if you have indicated that you do not wish to be contacted by us for such purposes. However, we will retain your details on a suppression list to help ensure that we do not continue to contact you.

Campaign Monitor

We use a third-party provider Campaign Monitor to deliver some of our newsletters and marketing communications. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. For more information, please see Campaign Monitor's https://www.campaignmonitor.com/policies/

Personal information used for marketing purposes will generally be retained by us for 2 years after you withdraw your consent but may be retained for longer in accordance with our Document Retention Policy (available on request) where we are required to do so by funders' requirements or the law.

People who contact us via social media

We use a third-party provider, Hootsuite to manage our social media interactions via our Facebook, Twitter and LinkedIn channels.

If you send us a private or direct message via social media the message will be stored on Hootsuite and the social media channel used for 12 months. It will not be shared with any other organisations.

People who call us

When you call us we collect Calling Line Identification (CLI) information.

We also offer a translation service for customers when English is not their first language, this is provided by a third-party company. The company that provides this service does not retain any information from the calls or record them.

People who email us

We can encrypt and protect email traffic. If not encrypted you should be aware that any emails we send or receive may not be protected in transit.

We will also monitor any emails sent to us, including file attachments, for viruses or malicious software. Please be aware that you have a responsibility to ensure that any email you send is within the bounds of the law.

Survey Monkey

From time to time, we use Survey Monkey to conduct surveys and gather feedback from data subjects. They will, therefore, process any personal data provided by us to enable surveys to be sent out or by the data subject in response to a survey. Survey Monkey's Privacy Notice is available at https://www.surveymonkey.com/mp/legal/privacy-policy/?ut_source=footer

Personal information gathered in this way will generally be retained by us for 2 years after you withdraw your consent but may be retained for longer in accordance with our Document Retention Policy (available on request) where we are required to do so by funders' requirements or the law.

When we receive a complaint from a person we make up a file containing the details of the complaint. This normally contains the identity of the complainant and any other individuals involved in the complaint.

We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.

We usually have to disclose the complainant's identity to whoever the complaint is about. This is inevitable where, for example, the accuracy of a person's record is in dispute. If a complainant does not want information identifying him or her to be disclosed, we will try to respect that. However, it may not be possible to handle a complaint on an anonymous basis.

We will keep personal information contained in complaint files in line with our retention policy. This means that information relating to a complaint will be retained for 7 years from closure. It will be retained in a secure environment and access to it will be restricted according to the ‘need to know' principle.

Similarly, where enquiries are submitted to us we will only use the information supplied to us to deal with the enquiry and any subsequent issues and to check on the level of service we provide.

We process personal data when dealing with complaints and enquiries to meet our and your legitimate interest in our being able to comply with your request and meet our obligations to you.