Updated June 2019

We, Us, Our, Connect Supply, Adrian Curtis Limited – refers to Adrian Curtis Limited

Adrian Curtis Limited is the data controller and is responsible for your personal data.

You refers to yourself or the organisation you represent.

Data Protection Legislation – refers to all applicable privacy and data protection laws including (i) the General Data Protection Regulation ((EU) 2016/679), the Data Protection Act 2018 and any further or additional national implementing laws, regulations and secondary legislation in England and Wales relating to the processing of Personal Data and the privacy of electronic communications, as amended, replaced or updated from time to time, including the Privacy and Electronic Communications Directive (2002/58/EC) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2003/2426).

1. Introduction

Connect Supply is an initiative run by Adrian Curtis Limited. We are a free network where churches of all sizes can access low cost, good quality resources and services. Members can share good practice and receive practical help to build their church and follow their God given vision. Connect Supply liberates church leaders from unnecessary administration and provides members with materials, resources and services at a significantly reduced cost compared to what churches can access on their own. To do this we need to obtain personal data from individuals representing churches, and information about the churches or organisations they represent so that we can manage their membership and inform them about resources, good practice, materials, services and provide practical help.

We respect your privacy and are committed to protecting personal data. This privacy policy will provide you with information about how we protect and use your personal data and the privacy rights and laws that protects you.

2. Purpose of this privacy policy

This policy will give you information about how we collect and processes your personal data through the Connect Supply network.

It is important that you read this privacy policy together with any other policies we may provide so that you are fully aware of how and why we are using your data. This policy supplements other notices and privacy policies and is not intended to override them.

3. Scope of this policy

3.1 Anonymous data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

3.2 Third-party links

Our website and other communications may include links to third-party websites, social media pages 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 services and are not responsible for their privacy statements. When you visit an external website or use a third party service, we encourage you to read their privacy policy.

4. Changes to this Privacy Notice and your duty to inform us of changes

We keep this privacy policy under regular review.

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.

5. What personal data do we receive?

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

  • Identity data (including your first name, last name, title, address, gender);
  • Contact data (including your address, church address, delivery address, email address, telephone contact numbers and social media contact information);
  • Financial Data (including bank account details for payments).
  • Transaction Data (including details about payments to and from you and other details of products and services you have purchased from us).
  • Technical Data (including internet protocol address, your login data, 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).
  • Profile data (includes your username and password, purchase history, preferences, feedback and survey responses);
  • Usage Data (including information about how you use our website, products and services].
  • Marketing and Communications data (including your preferences in receiving marketing from us and/or third parties and your communications preferences);

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, any data that can directly or indirectly identify you will be treated as personal data and will be used in accordance with this privacy policy.

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 genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

6. How is your personal data collected?

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

  • Direct interactions. You may give us data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for membership, request information about services, attend events complete a survey or contact us in any other way.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources including:
    • Technical data from analytics providers and search engines, based outside the EU.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
    • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

7. How will your personal data be used?

We will only use your data in circumstances where the data protection legislation allows us to. Most commonly, we will use your personal data in the following circumstances:

  • (a) Where we need to perform a contract with you;
  • (b) Where it is necessary for our legitimate interests (or those of a third party) and your interests;
  • (c) Where we need to comply with a legal obligation;
  • (d) Where we have received your informed and specific consent.

We have set out below, in a table format a description of all the ways we plan to use your personal data, and which of the legal bases we rely on.

Please 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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose

Type of data

Lawful basis for processing.

To provide you with marketing information regarding our membership and services which may be of interest to you

(a) Identity data

(b) Contact data

(c) Marketing and Communications data

(a) Necessary for our legitimate interests

(b) Consent

To process and deliver services:

(a) Manage payments, fees and charges

(b) Collect money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests

To register you as a member

(a) Identity data

(b) Contact data

Performance of a contract with you

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to take part in a survey or provide feedback

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests

To promote the work of Connect Supply or Adrian Curtis Limited

(a) Identity

(a) Necessary for our legitimate interests

(b) Consent

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

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests

To use data analytics to improve our website, products/services, marketing, events, customer relationships and experiences

(a) Technical

Necessary for our legitimate interests

 

8. Marketing

8.1 Promotional offers from us

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or have given your specific and informed consent to receiving that marketing.

8.2 Opting out                                                                                                             

You can ask us or third parties to stop sending you marketing messages at any time to do this email privacy@adriancurtis.co.uk. This will not apply to personal data provided to us other than in accordance with this privacy notice.

8.3 Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

9. How we protect your data

9.1 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, 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.

9.2 Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep some information for six years for tax and other legal purposes.

In some circumstances you can ask us to delete your data.

In some circumstances we will anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9.3 International Transfers

At this time, none of our external third parties are based outside the EEA. In the event that we engage an external third party which is based outside the EEA, their processing of your personal data would involve a transfer of data outside the EEA and will be dealt with in accordance with the section below.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries or organisations which have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

10. What 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.                                                                  

11. Your Rights

Under the data protection legislation you have a number of rights with regard to your personal data. You have the right to:

11.1 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.

11.2 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.

11.3 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, 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.

11.4 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.

11.5 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:

  • If you want us to establish the data’s accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • 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.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

11.6 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.

11.7 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.

11.8 Complaints

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.

12. Identity and contact details of controller and data compliance advisor

Adrian Curtis Limited is the controller of data for the purposes of the data protection legislation.

 

If you have any concerns as to how your data is processed, or if you have any questions about this privacy policy or our privacy practices more generally, you can contact our data compliance managers at privacy@adriancurtis.co.uk.

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