Privacy Notice

This is the privacy notice of Subject Revolution (‘we’, ‘our’, or ‘us’).

Our registered office is at Park View, Grantham.

Introduction

This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

Data Protection Officer

We have appointed a data protection officer (‘DPO’) who is responsible for ensuring that our privacy policy is followed.

Personal data we process

1. How we obtain personal data

The information we process about you includes information:

1. • you have directly provided to us

   • that we gather from third party databases and service providers

   • as a result of monitoring how you use our website or our services

1. Types of personal data we collect directly

When you use our website, we ask you to provide personal data. This can be categorised into the following groups:

1. • personal identifiers, such as your first and last names, your title and your date of birth

   • contact information, such as your email address, your telephone number and your postal addresses for billing, delivery and communication

   • account information, including your username and password

   • payment information, such as a debit or credit card number and expiry date and bank account details

   • records of communication between us including messages sent through our website, email messages and telephone conversations

   • marketing preferences that tell us what types of marketing you would like to receive

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The additional information we collect can be categorised as follows:

1. • information that confirms your identity

   • business information, including your business trading name and address, your company number (if incorporated), and your VAT number (if registered)

   • information that confirms your contact information

   • reviews and feedback about your business on other websites through which you sell your services

   • unsolicited complaints by other users

1. Types of personal data we collect from your use of our services

By using our website and our services, we process:

1. • your username and password and other information used to access our website and our services

   • information you contribute to our community, including reviews

   • your replies to polls and surveys

   • technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system

   • usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages

   • transaction information that includes the details of the products services you have bought from us and payments made to us for those services

   • your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.

1. Our use of aggregated information

We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

For example, we may aggregate usage information to assess whether a feature of our website is useful.

However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.

1. Special personal data

We do not collect any special personal data about you.

1. If you do not provide personal data we need

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 that contract.

In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.

If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

1. Information we process because we have a contractual obligation with you

When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal data.

We may use it in order to:

1. • verify your identity for security purposes when you use our services

   • sell products to you

   • provide you with our services

   • provide you with suggestions and advice on products, services and how to obtain the most from using our website

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

1. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be personal data.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, we ask you to agree to our use of non-essential cookies when you access our website.

If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us info@subjectrevolution.co.uk However, if you do so, you may not be able to use our website or our services further.

We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.

1. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

1. • whether the same objective could be achieved through other means

   • whether processing (or not processing) might cause you harm

   • whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

1. • improving our services

   • record-keeping for the proper and necessary administration of our business.

   • responding to unsolicited communication from you to which we believe you would expect a response

   • preventing fraudulent use of our services

   • exercising our legal rights, including to detect and prevent fraud and to protect our intellectual property

   • insuring against or obtaining professional advice that is required to manage business risk

   • protecting your interests where we believe we have a duty to do so

1. Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal data.

1. Information we process to protect vital interests

In situations where processing personal information is necessary to protect someone’s life, where consent is unable to be given and where other lawful bases are not appropriate, we may process personal information on the basis of vital interests.

For example, we may inform relevant organisations if we have a safeguarding concern about a vulnerable person.

How and when we process your personal data

1. Your personal data is not shared

We do not share or disclose to a third party, any information collected through our website.

1. Information you provide

We do store it, and we reserve a right to use it in the future in any way we decide

1. Job application and employment

If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.​​

 

 

Other matters

1. Your rights

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.

We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org

Control over your own information

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.

At any time, you may contact us to request that we provide you with the personal data we hold about you.

When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Please be aware that we are not obliged by law to provide you with all personal data we hold about you, and that if we do provide you with information, the law allows us to charge for such provision if doing so incurs costs for us. After receiving your request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

If you wish us to remove personally identifiable information from our website, you should contact us to make your request.

This may limit the service we can provide to you.

We remind you that we are not obliged by law to delete your personal data or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.

1. Communicating with us

When you contact us, whether by telephone, through our website or by email, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business.

We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

1. Complaining

If you are not happy with our privacy policy, or if you have any complaint, then you should tell us.

When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint.

We aim to investigate all complaints relating to user generated content. However, we may not be able to do so as soon as a complaint is made. If we feel that it is justified or if we believe that the law requires us to do so, we shall remove the content while do so.

Making a complaint may not result in the removal of the content. Ultimately, we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

If your complaint reasonably requires us to notify some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal data, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

1. Retention period

Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:

1. • to provide you with the services you have requested

   • to comply with other law, including for the period demanded by our tax authorities

   • to support a claim or defence in court

1. Compliance with the law

Our privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).

1. Review of this privacy policy

We shall update this privacy notice from time to time as necessary.

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Data protection policy

 

This policy sets out how Subject Revolution handles the personal data of its employees, customers,

suppliers and other third parties.

 

This policy is intended to ensure that we:

 

* Comply with data protection law and follow good practice;

 

* Protect the rights of team members, customers and partners;

 

* Are transparent about how we store and process individuals’ data;

 

• Are protected from the risks of a data breach.

 

Protecting the confidentiality and integrity of personal data is a critical responsibility that we take

seriously at all times. This policy is therefore intended to apply to the personal data that we process

about you. It also applies to you in situations where your role involves you processing data on our behalf.

This policy does not form part of any employee’s contract of employment, and we may amend it at any

time. It does not override any applicable national data privacy laws and regulations in countries where

we operate.

 

Scope

This policy applies to all personal data that we process regardless of the media on which that data is

stored, or whether it relates to past or present employees, workers, customers, suppliers, or any other

data subject.

Anyone who works for the Company, whether or not they are employees, must read, understand and

comply with this document when processing personal data. Any breach of the rules contained within

this policy may result in disciplinary action.

 

Data protection principles

We adhere to the principles relating to the processing of personal data, as set out in the GDPR. These

require personal data to be:

 

* Processed lawfully, fairly and in a transparent manner;

• Collected only for specified, explicit and legitimate purposes (“purpose limitation”);

* Adequate, relevant and limited to what is necessary in relation to the purposes for which it is

processed (“data minimisation”);

* Accurate, and where necessary, kept up to date (“accuracy”);

* Not kept in a form which permits identification of data subjects for longer than is necessary (“storage

limitation”);

* Processed in a way which ensures its security, using appropriate technical and organisational

measures to protect against unauthorised or unlawful processing, and against accidental loss,

destruction or damage (“integrity and confidentiality”);

 

In addition to these 6 core principles there are a number of other obligations on us (as the controller

of your data) and rights that you have in relation to your data (as data subject). These include

requirements that your personal data is:

 

* Not transferred to another country without appropriate safeguards in place;

 

* Made available to data subjects, who must be allowed to exercise certain rights in relation to their

personal data.

 

 

Fair, lawful and transparent processing

We must process your personal data lawfully, fairly and in a transparent manner.

What this means is that we can only process your data fairly and lawfully and for one of the specified

purposes (or legal bases) set out in the GDPR. These include the following:

 

* The data subject has given consent to the processing of his or her personal data for one or more

specific purposes;

 

* Processing is necessary for the performance of a contract to which the data subject is party or in

order to take steps at the request of the data subject prior to entering into a contract;

 

* Processing is necessary for compliance with a legal obligation to which the controller is subject;

 

* Processing is necessary in order to protect the vital interests of the data subject or of another natural

person;

 

* Processing is necessary for the performance of a task carried out in the public interest or in the

exercise of official authority vested in the controller; or

 

* Processing is necessary for the purposes of the legitimate interests pursued by the controller or by

a third party, except where such interests are overridden by the interests or fundamental rights and

freedoms of the data subject which require protection of personal data, in particular where the data

subject is a child.

 

When we collect personal data about you, whether directly from you or from a third party, then we are

obliged to provide you with certain information about that personal data including what we will do with

it, who we will share it with and what our legal basis for processing is. That information will be set out in a

Privacy Notice.

 

Consent

We can only process personal data on the basis of one or more of the lawful bases set out in the GDPR,

and listed above - these include with the consent of the data subject.

Consent can be difficult to obtain under the GDPR. It must freely given, specific, informed and

unambiguous.

In order to consent to the processing of their personal data, a data subject should indicate their

agreement either by a statement or by positive action. You cannot assume that consent has been given

in the absence of any express agreement.

Data subjects must be easily able to withdraw their consent at any time. We will keep records of all

consents, so that we can demonstrate our compliance with this data protection requirement.

 

Accountability

We are the Data Controller for your data. As the Controller we are responsible for

implementing appropriate technical and organisational measures to ensure compliance with the data

protection principles detailed above.

 

As part of that responsibility we will appoint a person(s) to be responsible for data protection and we

may appoint a suitably qualified Data Protection Officer. We will also take a number of other steps,

including to:

 

* Ensure and document GDPR compliance;

 

• Train Company personnel on the GDPR and on our associated policies and procedures.

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Purpose Limitation

When we collect personal data it must be only for explicit and legitimate purposes that are clear up

front. We may not process the data in any manner that is incompatible with these purposes.

If the purposes for data collection and processing change, then we must inform the data subject of

these new purposes, and if necessary, we must gain their renewed consent.

Data Minimisation

The data that we collect and process must be limited to what is strictly necessary and relevant for the

intended purposes. When any data is no longer needed for these purposes, we must then either delete

or anonymise it.

 

Accuracy

We must check the accuracy of any personal data at the point of collection, and at regular intervals

afterwards, and either delete or correct inaccurate or out-of-date personal data.

 

Storage Limitation

Personal data must not be kept in an identifiable form for any longer than is necessary for the stated

purposes for which the data is processed. Therefore, we must ensure that when personal data is no

longer needed, it is deleted or anonymised. We will require third parties to also delete or anonymise data

where and when applicable.

 

Integrity and Confidentiality

We must secure personal data by taking technical and organisational measures against unauthorised

or unlawful processing, and against accidental loss, destruction or damage. Such safeguards may

include the use of encryption and pseudonymisation. We will exercise particular care in protecting

special categories of personal data and criminal convictions data.

 

Personal Data Breaches

Should a breach of personal data occur, we will usually notify the appropriate regulator (unless it is

assessed that the breach is unlikely to result in a risk to the rights and freedoms of individuals) and, in

certain instances, the data subject. We are also obliged to keep a record of all personal data breaches.

 

Data subjects’ rights

The people whose data we hold (data subjects) have many rights regarding the processing of their

personal data. These include, but are not limited to, the following rights to:

 

* Withdraw consent to the processing of their personal data;

* Request access to their personal data that the company holds;

* Prevent our use of their personal data for direct marketing purposes;

* Ask us to erase any personal data that is no longer necessary for us to hold;

* Ask us to correct any inaccurate or out-of-date data;

* Prevent processing of data that is likely to cause damage or distress to the data subject or to anyone

else;

• Be notified of a data breach which is likely to result in high risk to their rights and freedoms.

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Record keeping

We are required by law to keep full and accurate records of all our data processing activities. These

records include:

 

* Data subjects’ consents to the processing of their personal data;

* The name and contact details of our Data Protection Officer, if applicable;

* Clear descriptions of the types of data that we hold, and of the types of data subjects whose data

we hold;

* The purposes of our data processing;

* The categories of recipients to whom the personal data has or will be disclosed;

* Details of any third-party recipients of personal data;

* Where possible the envisaged time limits for erasure of the different categories of data;

• Where possible, a description of the security measures in place.

 

Direct marketing

We are subject to certain rules and privacy laws when marketing to our customers. Customers generally

need to give us their consent for us to send them electronic direct marketing communications, for

example via emails, texts or automated calls. If a customer opts out of receiving direct marketing

communications, we must honour their request promptly.

 

Sharing personal data

You should generally only share personal data with third parties, such as service providers, under the

following circumstances:

 

* The third party needs to hold the data in order to provide the contracted services;

* The privacy notice given to the data subject has made it clear that their data will be given to third

parties for express purposes;

* The third party has agreed to comply with the necessary data security standards and procedures;

* There exists a GDPR compliant contract between both parties.

* The transfer of data complies with cross-border transfer restrictions.

* You may only share personal data with other employees or agents of the Company if the recipient

needs to have the data in order to fulfil their role.