1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can limit the collection, sharing and publication of your personal data.
1.5 In this policy, “we”, “us” and “our” refer to Autarki Social Limited. For more information about us, see Section 10.
2. The personal data that we collect
2.1 In this Section 2 we have set out the general categories of personal data that we process.
2.2 We may process data enabling us to get in touch with you (“contact data“). The contact data may include your name and email address. The source of the contact data is you.
2.3 We may process your website user account data (“account data“). The account data may include your account identifier, name, email address, creation and modification dates and website. The primary source of the account data is you, although some elements of the account data may be generated by our website.
2.4 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, email address and profile pictures. The source of the profile data is you.
2.5 We may process your personal data that are provided in the course of the use of our services and generated by our services in the course of such use (“service data“). The service data may include your membership status, membership subscription and information about which of our services you are using. The source of the service data is you and our services.
2.6 We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data“). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
2.7 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Purposes of processing and legal bases
3.1 In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
3.2 Operations – We may process your personal data for the purposes of operating our website and providing our services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
3.3 Publications – We may process account data, profile data and/or service data for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is consent.
3.4 Relationships and communications – We may process contact data, account data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors and service users, the maintenance of relationships, and the proper administration of our website, services and business.
3.5 Personalisation – We may process account data, service data and/or usage data for the purposes of personalising the content that you see on our website and through our services to ensure that you only see material that is relevant to you. The legal basis for this processing is consent.
3.6 Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
3.7 Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
3.8 Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.9 Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
4. Providing your personal data to others
4.1 We will not provide your personal data to a third party without your express consent except as set out below.
4.2 We may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. Your rights
6.1 In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
6.2 Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
6.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.[ You can access [your personal data] by visiting [URL] when logged into our website.]
6.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
6.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: [the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: [for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims].
6.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
6.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
6.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
6.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
6.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.11 If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
6.12 To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.13 You may exercise any of your rights in relation to your personal data [by written notice to us] OR [by [methods]][, in addition to the other methods specified in this Section 8].
7. Personal data of children
7.1 Our website and services are targeted at persons over the age of 18.
7.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
8. Updating information
8.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
9.1 We may update this policy from time to time by publishing a new version on our website.
9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
9.3 We [may] OR [will] notify you of [changes] OR [significant changes] to this policy [by email].
10. Our details
10.1 This website is owned and operated by Autarki Social Ltd.
10.2 We are registered in England and Wales under registration number 13134465, and our registered office is at 64 Nile Street, London, N1 7SR.
10.3 You can contact us:
(a) by email using the email address [email protected]
11. Data protection officer
11.1 Our data protection officer’s contact details are: Louise Creffield – [email protected]