PRIVACY NOTICE
PURPOSE OF THIS NOTICE
This notice describes how Equine Affinity South East Ltd collects and uses personal data about you, in accordance with the General Data Protection Regulation (GDPR), the Data Protection Act and any other national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK (‘Data Protection Legislation’).
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
ABOUT US
Equine Affinity South East Ltd (*hereafter referred to as Equine Affinity) is a company offering Equine Guided Learning & Therapy. We are registered in England and Wales as a limited company at Companies House (8292249) and our registered office is at 28 Wilton Rd, Bexhill on Sea, TN40 1EZ.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
Our Data Protection Officer, Ms C Bray, is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data. Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted here
HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain personal data about you, for example, when: you engage us to provide our services and also in the course of the provision of those services; you contact us by email, social media, telephone, or post.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
your contact details (such as your name, address, email and telephone numbers);
details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
details of any services you have received from us;
our correspondence and communications with you;
information about any complaints and enquiries you make with us;
Information we receive from other sources, such as: publicly available information; information provided by your employers/ supervisors/ course providers/directors (in which we are part of their programme); and/or teachers.
SPECIAL CATEGORIES DATA
Owing to the services that we offer, Equine Affinity needs to collect, store and process sensitive personal information (known as special category data) about you. Special category data is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and/or information concerning health.
We collect and process information concerning your health (health data) for the purpose of assessing the suitability of our services. Where we collect such information, we will only request and process the minimum necessary for specified purposes. The legal basis for this processing is the compliance with our legal obligations, to protect your vital interests and consent.
HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for purposes necessary for the performance of our contract with you to comply with our legal obligations.
We may process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data.
We may process your personal data for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal data then you have the right to withdraw your consent to processing for such specific purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
carry out our obligations arising from any agreements entered into between you, or our clients and us (which will typically be for the provision of our services);
carry out our obligations arising from any agreements entered into between our clients and us (which will typically be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
provide you with information related to our services and our events and activities that you request from us or which we feel may interest you, provided you have consented to be contacted for such purposes;
seek your feedback on the services we provide
notify you about any changes to our services.
collect and store your personal data as part of our legal obligation for business accounting and tax purposes; and
periodically send you marketing information, we have assessed would be beneficial to you as a customer and in our interests. Such information will be non-intrusive and is processed only if you have consented to this.
If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
DATA RETENTION
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected.
When assessing the appropriate retention period for your personal data, we take into consideration:
the requirements of our business and the services provided;
any statutory or legal obligations;
the purposes for which we originally collected the personal data;
the lawful grounds on which we based our processing;
the types of personal data we have collected;
the amount and categories of your personal data; and
whether the purpose of the processing could reasonably be fulfilled by other means.
CHANGE OF PURPOSE
Where we need to use your personal data for any reason, other than the purpose for which it was initially collected, we will only do so where said reason is compatible with the original purpose.
Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.
DATA SHARING
Why might you share my personal data with third parties?
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us or where we have another legitimate interest in doing so.
Which third-party service providers process my personal data?
“Third parties” includes third-party service providers. The following activities may be carried out by third-party service providers: IT and cloud services, professional advisory services and administration services.
All of our third-party service providers are required to take commercially reasonable and appropriate security measures to protect your personal data. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal data with other third parties, for example if applicable in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
We will not transfer the personal data we collect about you outside of the EEA. Where delivery of our assignments are undertaken outside the EEA, we will ensure that any data shared is treated with the exacting standards and conditions prescribed by, and in accordance with, EU and UK Data Protection laws.
There is an adequacy decision by the European Commission in relation to these countries therefore they will be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation.
Should you require further information about this protective measure, please contact us using the contact details outlined here.
DATA SECURITY
We have put in place commercially reasonable and 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, 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 data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
Request correction of the personal data that we hold about you.
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 exercised your right to object to processing (see below).
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 basis.
Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our data protection point of contact Ms C Bray, as detailed here
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information. This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, it could be in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our data protection point of contact Ms C Bray, as detailed here.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be provided to you here on the Equine Affinity website (www.equineaffinity.co.uk)
CONTACT US
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact:
Ms C Bray at info@equineaffinity.co.uk
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Telephone – 0303 123 1113 (local rate) or 01625 545 745
Website – https://ico.org.uk/concerns