General Data Protection Regulation
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General Data Protection Regulation
The GDPR, which takes effect May 25, 2018, is designed to unify data privacy requirements across the European Union (EU). If you market to or process the information of EU Data Subjects – which include end users, customers and employees – you need to be compliant with these key requirements.
1 - IMPORTANT NOTICE
1.1 This is the Privacy Notice of Artful Toddler Limited (Company Number 08197668) whose registered office is at 41 Tylecote Crescent, Little Haywood, Staffordshire ST18 0TA (“Artful Toddler”, “we”, “us” or “our”) and sets out how Artful Toddler collects and processes your personal data. This Privacy Notice also provides certain information that is legally required and lists your rights in relation to your personal data.
1.2 We take our data protection responsibilities very seriously and we comply with all applicable Data Protection Legislation in force from time to time. For the purposes of this Privacy Notice, “Data Protection Legislation” means: (i) the Data Protection Act 1998 (“DPA”) and all related regulations in force from time to time; or (ii) with effect from 25 May 2018, the EU Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) (“GDPR”) and any laws in England giving effect to its provisions.
1.3 This Privacy Notice relates to personal information identifying you or your child/children. We refer to this information throughout this Privacy Notice as “personal data” and section 2 sets out further detail of what this includes.
1.4 Please do read this Privacy Notice to understand how we may use the personal data of you and your child.
1.5 This Privacy Notice may vary from time to time so please check it regularly.
2 - THE PERSONAL DATA WE COLLECT ON YOU
We may collect the following personal data about you and your child/children:
2.1 personal data you provide to us in person, via our websites or by any other form of communication;
2.2 personal data in the form of images or video footage that is taken or captured at one or any of Artful Toddlers venues or events;
2.3 personal data you provide when applying to either become a franchise owner, or for any jobs advertised or submissions for speculative job applications and/or your CV;
2.4 personal data gathered using cookies;
2.5 personal data you provide if you enter any competition or promotion; and
2.6 details of your visits to our website including but not limited to traffic data, location data, weblogs and other communication data
3 - KEY INFORMATION ABOUT YOUR PERSONAL DATA
3.1 Data controller and contact details
3.1.1 For the purposes of the Data Protection Legislation, we are the controller of the personal data you provide to us (in the DPA this is referred to as a “data controller”) and as a controller we process (or ‘use’) the personal data we hold on you in accordance with this Privacy Notice.
3.1.2 If you need to contact us in connection with our processing of your personal data, then you can do so at firstname.lastname@example.org.
3.2 How we use your personal data
3.2.1 We would like to use the personal data you provide to us for a number of different purposes. These are as follows:
(a) where, in the provision of any of our goods and services to you and your child/children, we need to use the information you provide to us about your child/children’s health;
(b) where we would like to use photos or images taken of you or your child in promotional and marketing materials;
(c) where we have new or updates to our services and activities which we think you will be interested in; or
(d) where an opportunity arises to work for or with Artful Toddler.
3.3 Withdrawing your consent
You may at any time withdraw the consent you give to our processing your personal data for those purposes set out in section 3.2 above. If you have any issues in connection with this process, then please contact us using the details set out above.
3.4 How we use your personal data – where your consent is not obtained
3.4.1 In some instances we may not obtain your consent to our processing of your personal data and instead we can rely on another lawful basis to do so. Examples for this, may be because we need to use your personal data in order to provide you with the services or goods you have elected to receive from us (i.e. in the ordinary course of our business), contact you in the case of an emergency or unforeseen circumstance and to improve our service offering to you over time.
3.4.2 These purposes for which we can use your personal data are set out below:
How we use your personal data
To perform our contractual obligations to you. This would include our fulfilling orders you have placed for services or goods (including online), contacting you in relation to any issues with your order or where we need to provide your personal data to our franchisees and their authorised personnel (including, but not limited to, all authorised teachers and administrative personnel) so that they may provide you with such goods or services and communicate with you about them (e.g. where there is a change to the time or location of a class).
To comply with our own legal obligations, e.g. health and safety legislation, or to assist in an investigation (e.g. from the Police).
To share your personal data with our franchisees and their authorised personnel (including, but not limited to, all authorised teachers and administrative personnel) so that we can add your child/children to the register for each class.
To use your personal data to operate our business, but otherwise than in performing our contractual obligations to you (and includes our providing your personal data to our franchisees and their authorised personnel (including, but not limited to, all authorised teachers and administrative personnel) for the same purposes).
Our ‘legitimate interests’ for the purposes of Data Protection Legislation are as follows:
(i) notifying winners of online competitions;
(ii) sending you surveys in connection with our goods and services;
(iii) to send you important notices such as communications about changes to our terms and conditions and policies;
(iv) to assist in the investigation of suspected illegal or wrongful activity. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
(v) to deal with any misuse of the website/s;
(vi) to provide you with important real-time information (usually by email) about classes or services you have booked (e.g. a change of time or location of the class due to unforeseen circumstances);
(vii) to send you information you have requested;
(viii) to deal with your enquiries;
(ix) where you have submitted interest in becoming a franchise owner or for a job, we may keep your details on file for future reference and we may send you information about franchise and job opportunities;
(x) to develop, deliver and improve our goods or services;
(xi) to help us develop our website to be more useful to you;
(xii) for internal purposes for hosting, research, analysis, testing, monitoring, customer communication, risk management and administrative purposes;
(xiii) to protect and defend our rights or property;
(xiv) to sell, make ready for sale or dispose of our business in whole or in part including to any potential buyer or their advisers; or
To use the health-related personal data you provide to us about your child/children to protect the vital interests of you and your child/children in situations where you are physically or legally incapable of giving consent for us to do so. For example, this would enable us to make this type of personal data available to each of our franchisees and their authorised personnel (including, but not limited to, all authorised teachers and administrative personnel) in situations where we and/or our franchisees are required to comply with a specific legal requirement and there is not time to gain your consent. This would especially be relevant in an emergency or simply to enable you to take classes at different venues with different franchisees.
3.4.3 We will do our best to inform you when we carry out any of the above activities, but it may be that we are unable to do so in each case
3.5 Who receives the personal data you provide to us
3.5.1 Other than as set out in this Privacy Notice, we do not share your personal data with any third party that is not connected to us. The Artful Toddler business operates through a franchise network, so we sometimes share the personal data we collect from you with each of our franchisees (who may also share it with their authorized teachers and administrative personnel) so that the franchisees can use your personal data for the purposes set out above.
3.5.2 In addition, we may disclose the personal data you provide to us to our group companies and affiliates or third-party data processers who may process data on our behalf for the purposes set out in section 3.4 above.
3.6 Transfers of your personal data to other countries
Wherever possible, the personal data we collect from you is held within the European Economic Area (“EEA”). It is however possible that in the
future such personal data may be transferred, stored and/or processed outside the European Economic Area (“EEA”) by our third-party processors. By submitting your personal data, you agree to this transfer, storing and/or processing. You should be aware that countries outside the EEA may not offer the same level of data protection as the United Kingdom, however we will take reasonable steps to ensure that your data is treated securely and in accordance with the DPA.
3.7 How long we will hold your personal data for
We will only hold your personal data for so long as is necessary for us to do so, however because this depends in each case on how each of our customers interact with us, we keep the length of time that we hold your personal data for under continual review. To do this we regularly review the personal data we hold and which of our customers are still attending Artful Toddler activities. Where we no longer need to process your personal data for the purposes set out in this Privacy Notice then we will delete your personal data from our system. This means that if you or your child/children does not attend an Artful Toddler activity for a long period of time and then return, we may not have retained your details. In such instances, you may need to supply these details to us again in order to receive our services and goods.
3.8 Why should you provide us with personal data?
3.8.1 Your personal data belongs to you and your family and we would like you to be comfortable with the level of information you disclose to us: you do not have to provide us with any personal data if you do not wish to do so.
3.8.2 However, please be aware that we do need to use your personal data to fulfil our contractual obligations to you and to provide you with our services and goods.
3.8.3 Where we ask for your consent to process your personal data, you are free to withdraw any consent you may give. Please note, however, that where you do withdraw your consent or otherwise object to our processing of your personal data then this will impact our ability to provide you with services and goods (e.g. if we cannot contact you to tell you about a venue change or bookings for new terms etc).
4 - LINKS TO OTHER WEBSITES