This privacy policy tells you what to expect us to do with your personal information.
Second Spring, Unit 145955, PO Box 6945, London, W1A 6US
We collect or use the following information to provide services and goods, including delivery:
· Names and contact details
· Payment details (including debit/credit card or bank information for repeat or standalone payments)
· Health information (including health conditions)
· Website user information (including user journeys and cookie tracking)
· Information relating to compliments or complaints
We collect or use the following information to prevent, detect, investigate or prosecute crimes:
· Names and contact information
· Financial transaction information
We collect or use the following information for service updates or marketing purposes:
· Names and contact details
· Marketing preferences
· Location data
· Purchase or viewing history
· Website and app user journey information
· Records of consent, where appropriate
We collect or use the following information for research or archiving purposes:
· Names and contact details
· Location data
· Purchase or viewing history
· Website and app user journey information
· Personal information used for administration of research
· Personal information used for the purpose of research
· Records of consent, where appropriate
We collect or use the following information to comply with legal requirements:
· Name
· Contact information
· Financial transaction information
We collect or use the following personal information for dealing with queries, complaints or claims:
· Names and contact details
· Payment details
· Purchase or service history
· Relevant information from previous investigations
· Customer or client accounts and records
· Financial transaction information
· Correspondence
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website. Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection
rights and the exemptions which may apply on the ICO’s website:
· Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. · Your right to erasure - You have the right to ask us to delete your personal information.
· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information.
· Your right to object to processing - You have the right to object to the processing of your personal data.
· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for collecting or using personal information to provide services and goods are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o Legitimate interest for collecting or using personal information enables us to provide you with relevant service opportunities based on your prior interactions with Second Spring. This also enables us to work with third party providers such as Stripe, a payment provider to process payments.
· Vital interests – collecting or using the information is needed when someone’s physical or mental health or wellbeing is at urgent or serious risk. All of your data protection rights may apply, except the right to object and the right to portability.
Our lawful bases for collecting or using personal information to prevent, detect, investigate or prosecute crimes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object. · Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o Legitimate interest for collecting or using personal information helps us to keep individuals safe, to prevent, detect, investigate or prosecute crimes.
Our lawful bases for collecting or using personal information for service updates or marketing purposes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o Collecting or using personal information enables us to provide appropriate service updates and opportunities that the individual may benefit from and may otherwise not be aware of.
Our lawful bases for collecting or using personal information for research or archiving purposes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
o Collecting and using personal information for research and archiving purposes benefits individuals by supporting the improvement of services delivered and approach taken by Second Spring to make them relevant.
Our lawful bases for collecting or using personal information for legal requirements are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Directly from you
· Third parties: · Third parties may include a hiring or partner organisation, where clients are identified by them and connected with Second Spring for service delivery, with their consent.
We will retain your personal information for as long as necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
Stripe - financial processing, UK This data processor does the following activities for us: Processes payments.
· Professional or legal advisors
· Financial or fraud investigation authorities
· Relevant regulatory authorities
· External auditors or inspectors
· Professional consultants
· Organisations we’re legally obliged to share personal information with
· Emergency services
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice. If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO. The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF Helpline number: 0303 123 1113 Website: https://www.ico.org.uk/make-a-complaint
6 November 2024
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