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GTTSPT PRIVACY POLICY

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1. INTRODUCTION

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Greek Thomson Sixty Steps Preservation Trust Ltd (GTSSPT Ltd) is committed to protecting your privacy and security. This policy explains how and why we use your personal data, to ensure you remain informed and in control of your information.

GTSSPT Ltd will ask its contacts to “opt-in” for marketing communications. This is due to the rules which govern how we can communicate with you and EU legislation on personal data (the General Data Protection Regulation (EU) 2016/679). Therefore, our approach relies on you giving us your consent about how we can contact you for marketing purposes.

You can decide not to receive marketing communications or change how we contact you at any time. If you wish to do so please contact us by emailing thesixtystepsglasgow@gmail.com or by writing to GTSSPT Ltd, 27 Kelvinside Terrace South, Glasgow G20 6DW, United Kingdom.

We will never sell your personal data, and will only ever share it with organisations we work with where necessary and if its privacy and security are guaranteed.  Details of such organisations are included below in this policy.

Questions?

Any questions you have in relation to this policy or how we use your personal data should be sent to thesixtystepsglasgow@gmail.com.

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2. ABOUT US

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Your personal data (i.e. any information which identifies you, or which can be identified as relating to you personally) will be collected and used by the GTSSPT Ltd (Company registration number SC277072), with the primary aim of delivering information to you about the activities of the trust and any connected organisations.

For the purposes of data protection law, GTSSPT Ltd will be the controller of your personal data.

GTSSPT Ltd is a registered charity  -  registration number SC037773

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3. WHAT INFORMATION WE COLLECT

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Personal data you provide

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We collect data you provide to us through our contact form and website. This includes information you give when registering with us or communicating with us such as contact information (including your name, email, and message) when you contact us through our website.

Information created by your involvement with GTSSPT Ltd

Your activities and involvement with GTSSPT Ltd will result in personal data being created.

Information from third parties

We may receive personal data (including name, email) about individuals from third parties organisations we are partnering with (for example, if you provide your information to another organisation we’re collaborating with on a project).  When we receive such personal data we become the controller of it.

Also, as explained in Section 11 (Cookies and links to other sites), we may use third parties to help us conduct research and analysis on personal data (and this can result in new personal data being created).

We may collect information from social media, such as LinkedIn,  Twitter and Facebook, including if you post on one of our social media pages.

Health & Safety

For health & safety, including any incident occurring at on our property, at one of our events or involving one of our  members/trustees (including Associates) then we’ll keep a record of this (which may include personal data and special category personal data).

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4. HOW WE USE INFORMATION

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We only use your personal data where it is necessary in order to:

  • enter into, or perform, a contract with you;

  • comply with a legal duty, such as health and safety legislation and tax reporting requirements;

  • protect your vital interests, such as in the event of an emergency;

  • for our own (or a third party’s) legitimate interests, provided your rights don’t override these, such as conducting investigations, which may be on behalf of a client, and reports following such investigations and to send communications to you regarding other courses that may be of interest to you following your completion of a course with us.  You can object to us using your personal data for such purposes at any time by emailing thesixtystepsglasgow@gmail.com or by writing to GTSSPT Ltd, 27 Kelvinside Terrace South, Glasgow G20 6DW, United Kingdom.

We only ever use your personal data for marketing purposes with your consent and we’ll only use your information for the purpose or purposes it was collected for (or else for closely related purposes):

Marketing

We use personal data to communicate with people, to promote GTSSPT Ltd. This includes keeping you up to date with our news, updates, discussion topics and other topics of interest. For further information on this please see Section 6 (Marketing).

Administration

We use personal data for administrative purposes (i.e. to issue newsletters and invitations to events). This includes:

  • maintaining databases of our subscribers;

  • helping us respect your choices and preferences (e.g. if you ask not to receive marketing material, we’ll keep a record of this)

 

5. DISCLOSING AND SHARING DATA

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We will never sell your personal data. If you have opted-in to marketing, we may contact you with information about our carefully selected partners, but these communications will always come from GTSSPT Ltd and are usually incorporated into our own materials, such as newsletters.

We use marketing companies to assist with our marketing activities, which will have access to your personal data for this purpose only.  For example, our newsletter communications are sent using MailChimp, a US-hosted third party provider, who are certified as adhering to the EU-US Privacy Shield. We also use services offered by our website provider, Wix

Wix can store your data in a number of locations.
Your personal information may be stored in data centres located in the United States of America, Ireland, South Korea, Taiwan and Israel. They may use other jurisdictions as necessary for the proper delivery of our services and/or as may be required by law.

Wix is a global company that respects the laws of the jurisdictions it operates within. The processing of the User Customer Data may take place within the territory of the European Union, Israel or a third country, territory, or one or more specified sectors within that third country, of which, the European Commission has decided that it ensures an adequate level of protection (transfer on the basis of an adequacy decision). 

Important:

Any transfer to a third country, outside the European Union, that does not ensure an adequate level of protection according to the European Commission, will be undertaken in accordance with the Standard Contractual Clauses (2010/87/EU) set out in Appendix 1 of the Wix Data Processing Agreement (DPA) 

The security of sensitive data is of extreme importance to Wix and it is 100% committed to data protection.

Occasionally, where we partner with other organisations, such as event partners or co-sponsors of events, we may also share information with them, for example, if you register to attend an event being jointly organised by us and another organisation. We’ll only share information when necessary and details will be included on the relevant booking form/confirmation.

 

6. MARKETING

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From 17th October 2020, GTSSPT Ltd will ask individuals to “opt-in” for most communications. This includes all our marketing communications (the term marketing is broadly defined and, for instance, covers information about our activities and newsletters).

This means you’ll have the choice as to whether you want to receive these messages.

You can decide not to receive communications. If you wish to do so please contact us by emailing thesixtystepsglasgow@gmail.com or writing to GTSSPT Ltd, 27 Kelvinside Terrace South, Glasgow, United Kingdom, G20 6DW, United Kingdom

What does ‘marketing’ mean?

Marketing does not just mean offering things for sale, but also includes:

  • news and information about events we are attending;

  • annual greetings cards;

  • other relevant news and information.

When you receive a marketing communication, we may collect information about how you respond to or interact with that communication, and this may affect how we communicate with you in future.

Newsletters

Periodical newsletters are issued to keep people informed about the activities of GTSSPT Ltd. We send these out to all marketing contacts and you can choose to unsubscribe from general marketing communications and/or update your newsletter subscription preference at any time.

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8. HOW WE PROTECT DATA

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We employ a variety of physical and technical measures to keep your data safe and to prevent unauthorised access to, or use or disclosure of your personal information.

Electronic data and databases are stored on secure computer systems and we control who has access to information (using both physical and electronic means).

Payment security

We use 3rd party payment providers (PayPal and WorldPay) to handle your card transaction. We do not receive your card details. When using a card for payment the individual will be directed to the relevant card processing company. The card processing company will become the controller of your personal data regarding the payment. Therefore, you should review the relevant card processing company's privacy policy.

Of course, we cannot guarantee the security of your home computer or the internet, and any online communications (e.g. information provided by email or our website) are at the user’s own risk.

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9. STORAGE

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Where we store information

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GTSSPT Ltd’s operations are based in the UK and we store our data within the European Union. Some organisations which provide services to us may transfer personal data outside of the EEA, but we’ll only allow them to do so if your data is adequately protected. For example, we may use MailChimp, a US-hosted third party provider, who are certified as adhering to the EU-US Privacy Shield. We also use services offered by our website provider, Wix

Wix can store your data in a number of locations.
Your personal information may be stored in data centres located in the United States of America, Ireland, South Korea, Taiwan and Israel. They may use other jurisdictions as necessary for the proper delivery of our services and/or as may be required by law.

Wix is a global company that respects the laws of the jurisdictions it operates within. The processing of the User Customer Data may take place within the territory of the European Union, Israel or a third country, territory, or one or more specified sectors within that third country, of which, the European Commission has decided that it ensures an adequate level of protection (transfer on the basis of an adequacy decision). 

Important:

Any transfer to a third country, outside the European Union, that does not ensure an adequate level of protection according to the European Commission, will be undertaken in accordance with the Standard Contractual Clauses (2010/87/EU) set out in Appendix 1 of the Wix Data Processing Agreement (DPA) 

The security of sensitive data is of extreme importance to Wix and it is 100% committed to data protection.

How long we store information

We will only use and store information for so long as it is required for the purposes it was collected for. How long information will be stored for depends on the information in question and what it is being used for. For example, if you ask us not to send you marketing emails, we will stop sending you emails for marketing purposes, and keep a record of your preference not to be emailed.

We continually review what information we hold and delete what is no longer required. We never store payment card information.

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10. KEEPING YOU IN CONTROL

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We want to ensure you remain in control of your personal data. Part of this is making sure you understand your legal rights, which are as follows:

  • the right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of the personal information we hold (this is known as subject access request);

  • the right to have your data erased (though this will not apply where it is necessary for us to continue to use the data for a lawful reason);

  • the right to have inaccurate data rectified;

  • the right to object to your data being used for marketing or profiling; and

  • where technically feasible, you have the right to personal data you have provided to us which we process automatically on the basis of your consent or the performance of a contract. This information will be provided in a common electronic format.

Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so.

If you would like further information on your rights or wish to exercise them, please email thesixtystepsglasgow@gmail.com

You can complain to GTSSPT Ltd about data issues directly by contacting us by using the details set out above.

If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you can complain to the UK Information Commissioner’s Office which regulates and enforces data protection law in the UK. Details of how to do this can be found at www.ico.org.uk

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11. COOKIES AND LINKS TO OTHER SITES

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Cookies

Our website uses local storage (such as cookies) to provide you with the best possible experience and to allow you to make use of certain functionality. Further information can be found in our Cookies Policy at GTSSPTwww.sixtysteps.org/cookiepolicy.

Links to other sites

Our website contains hyperlinks to many other websites. We are not responsible for the content or functionality of any of those external websites (but please let us know if a link is not working by using the 'Contact' link at the bottom of the page).

If an external website requests personal information from you (e.g. in connection with an order for goods or services), the information you provide will not be covered by GTSSPT Ltd’s Privacy Policy. We suggest you read the privacy policy of any website before providing any personal information.

When purchasing goods or services from any of the businesses that our site links to, you will be entering into a contract with them (agreeing to their terms and conditions) and not with GTSSPT Ltd.

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12. CHANGES TO THIS PRIVACY POLICY

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We’ll amend this Privacy Policy from time to time to ensure it remains up-to-date and accurately reflects how and why we use your personal data. The current version of our Privacy Policy will always be posted on our website.

This Privacy Policy was last updated on 22nd November 2020

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