Summary of privacy notice
This version of the privacy notice was last updated on the 9th of November 2023. We recommend that you save a copy from the day you have read and agreed to this policy.
always possible will make every effort to protect the personal information that you provide us and are committed to respecting your right to privacy. By personal information we mean your name, contact details and any other information you give us.
- Please keep your personal details accurate and up-to-date
- We only collect personal information from you when you sign up to our mailing list, register for an event with us, complete a survey or form, or enter into a contract for services
- We do not sell your personal details on. We may share this information only with organisations we hire to run our services, or where we are required to do so by contract or law.
- We do not use ‘remarketing’ and do not promote adverts to you elsewhere on the internet based on how you use our site.
- We may contact you occasionally for monitoring, evaluation, or marketing purposes but you can opt out at any time.
- It describes how always possible ltd (“we”, “us” or “our”) collects, protects and uses the personal information we collect on our Websites and to deliver our contracts.
The data controller for the Websites is always possible ltd who can be contacted on firstname.lastname@example.org
You can also find out about controlling your cookies at http://www.youronlinechoices.com/uk/.
If you have any requests concerning your personal information or any queries as to how we use your personal information please contact us.
The Privacy Notice
This is a privacy notice by always possible ltd covering all communication users and clients may have with us through our Websites (alwayspossible.co.uk, thepossibilityclub.org) and on our social media channels. It also covers anyone who engages in a contract with us (eg clients, suppliers, staff).
We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to let you know how we look after your personal data. We’ll also tell you about your privacy rights and how the data protection laws protect you.
Our privacy notice is provided in sections as below. We may update this notice from time to time and we will let you know any significant changes through notifications on our site.
1. WHO WE ARE AND IMPORTANT INFORMATION
What is the purpose of this privacy notice?
This privacy notice aims to give you information on how we collect and process your personal data through your use of any of our Websites; including any data you may provide when you sign up to our mailing list, register for an event, or interact with us.
Our services and Websites are not intended for children and we require that anyone under the age of 16 gain consent to register on the website from their parent, carer or guardian who has had the opportunity to read and understand our privacy policies and the terms and conditions of use. If you register with us and are under 16, you confirm that you have gained this consent.
You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
always possible ltd is the controller and responsible for your personal data (collectively referred to as “COMPANY”, “we”, “us” or “our” in this privacy notice). Our contact details are email@example.com or you can write to us at always possible ltd, 483 Green Lanes, London, N13 4BS.
Third-party links outside our control
This website and emails we send you may include links to third-party websites, plug-ins 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 websites and are not responsible for their privacy statements.
When you leave our websites, we encourage you to read the privacy notice of every website you visit.
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be directly or indirectly identified. You can find out more about personal data from the Information Commissioners Office.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes the personal characteristics, name, and information submitted to us via mailing list or event sign-up forms.
- Contact Data includes email addresses and any postal or contact telephone numbers you provide us when registering with us or making contact in any mode (such as email, phone call or via social media message).
- Usage Data includes information about the pages you visit on our website and the platforms you came from to our website.
- Financial Data includes your bank account or payment method information ONLY when you make payments to us or request that we make a payment to you.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. ‘Aggregated data’ may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you on our Website (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.
If you work for us, or we’re providing a service for which the contract requires equality and diversity monitoring, we may ask you to volunteer this information at your will and we will store and process this data on a separate system to our customer facing website, using strict internal procedures. Financial data you provide to allow us to pay you is also treated with the strictest of privacy and is again subject to our internal procedures.
If you fail to provide personal data
Where we need to collect your 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. In this case, we may have to cancel the contract but we will notify you if this is the case at the time. We do require enough information to ensure that we are working with a reputable entity and can serve any court summons or requests for payments not made where necessary.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you. These methods include:
- Directly. You may give us your Identity or Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Sign up to our mailing list
- Request information about our services or book a call
- Register for events we are running
- Enter into a contract with us
- Directly within a financial transaction. When you send us your details to make payments, or you make a payment to us.
- Indirectly. When you log in to our websites we may record the pages visited (please note we ONLY track usage on our own websites and do not follow you to other platforms or sites).
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- To send you information about programmes or events you have registered for or a service you have commissioned from us. You can opt in to further communications from us, such as our general newsletters. You can unsubscribe from our emails or opt out of them at any time.
- Performance of Contract which means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, the shortlisting of job applicants during recruitment).
- Legitimate Interest which means our interest in conducting and managing our business to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Please contact us if you would like further information about how we assess our legitimate interests against any potential impact on you.
- To comply with a legal or statutory obligation. This means processing your personal data where it is necessary for compliance with a common law or statutory obligation.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
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/Activity||Type of data||Lawful basis for processing data and useful information|
|To send you news about our services, or updates about programmes or events you have registered for.|
(c) Special category
Consent given when you actively register. We can delete this information when requested to do so if you tell us what data you want removed.
For certain programmes or events we may have a contractual obligation to request special category data (eg ethnic origin) for equality and diversity monitoring purposes. It will be made clear to you why we are asking for that information and there will usually be a ‘prefer not to say’ option. We take additional measures to protect special category data.
|To monitor the performance of our websites and analyse how they are used.||(a) Usage||Performance of our contracts.|
|To send information and updates or request feedback about work undertaken as part of an existing or previous contract.|
|Performance of our contracts.|
|To communicate with you about any queries you send us – via email, phone or any other method.||(a) Contact||Legitimate Interest. In order for us to reply to you we must know how to communicate with you. This information may be stored with our service providers for email, telephone and similar services. We can delete this information when requested to do so if you tell us what data you want removed.|
|To process financial transactions|
Performance of a contract – for us to receive a payment from you or make a payment to you. This data will typically be held for the purpose of auditing and legal compliance.
|Research and evaluation|
|Performance of a contract – when we are conducting research or evaluation we may collect personal and/or behavioural information about you in order to make judgements on a service or product on behalf of a client. We will always tell you when we are doing this and how this data will be used. Your information will be stored safely and deleted within 6 months of the end of the project. Where possible, any behavioural data will be anonymised.|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may send you email communications with news, opportunities and offers relevant to you. You can unsubscribe at any time.
Third-party data sharing
We never sell your personal data or provide access to a third party for their own purposes. Third parties may have access to data only where they are under contract with us for a provision of a service, and they may not use it for any other purpose. For example, some of our suppliers currently include:
|Who||Why / What data|
|Siteground Hosting Ltd||All information stored on alwayspossible.co.uk is hosted on servers run by Siteground Hosting Ltd. They will not contact you directly.|
|WordPress, Mailchimp||Our website and newsletter may contain data such as name + image (eg staff members, event speakers, testimonials). You can request this data be updated or deleted at any time.|
|Google LLC||Emails you send us and we send you may be stored and processed by our email inbox and transactional service providers. Our retention and archiving procedures ensure timely deletion of project-related emails.|
|Google LLC, Monday.com, Slack Technologies Limited||Storage of our project files and data which enables us to run our organisation, manage projects and provide our services.|
|Hubspot, eventbrite, Zoom||When you complete a form to register for an event or programme and/or sign up to our mailing list, one or more of these services may be used.|
|Google LLC, Hubspot, Survey Monkey, Monday.com||Services we use for the creation and distribution of surveys and forms. We use these for research and evaluation purposes in order to carry out contracts or for the improvement of our services.|
|Mighty Networks||The online community platform that The Possibility Club is hosted on.|
|Google LLC, Liidio Oy, Siteground Hosting Ltd||Usage data only. Our website & service monitoring providers will collect data including using Cookies and through IP addresses.|
We will tell you explicitly if we need to pass any other data to another third party for processing in order to perform a contract.
You can ask us to stop sending you marketing messages at any time by clicking the unsubscribe link in the footer of the email.
Even if you opt out of receiving marketing messages, we may have an obligation to continue to store your data if it is necessary to comply with the law, keep you safe or fulfil a contract for any service you have with us.
No personal information is stored in the cookie that is issued by the site. The value stored in the cookie is an anonymous identifier, which is not linked to any other personal information you may give us during your visit.
If you do not wish to receive these cookies you can disable them in your browser. Please refer to your browser instructions or help screen to learn more about how to do this. However, should you decide to disable any cookies placed on your computer it may affect the functionality of the Website(s).
You can also find out more about controlling your cookies at http://www.youronlinechoices.com/uk/.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how we may process data for a new purpose that is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will contact you and explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. WHO WE SHARE YOUR PERSONAL DATA WITH
We may have to share your personal data with the parties set out below as outlined in section 4 above.
- Suppliers to us in managing our Websites and services as identified in section 4 above.
- Other third parties may access your data when working with us in these circumstances:
- Providers acting as processors in an administrative and IT capacity which may change from time to time. We have contracts with everyone and have identified their privacy policies.
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide services that allow us to comply with our legal duties, especially those in relation to our accounting and banking provision.
- HM Revenue and Customs, regulators and other authorities acting as processors based in the United Kingdom (or who comply with UK privacy laws) who require reporting of processing activities in certain circumstances.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Some of our providers are based outside of Europe. All suppliers are subject to the conditions we’ve specified in section 5 and we have undertaken a full audit to identify the location of suppliers and ensure they have the appropriate and compliant mechanisms in place for handling the data we store with them.
7. 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.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To decide 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 requirements.
By law we have to keep basic information about our customers who engage with us in financial transactions for the period specified by the UK tax authorities. We must also keep a record of certain details provided on registration forms for funded business programmes for the period specified by the funders.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you
- The right to request that we correct any personal data if it is found to be inaccurate or out of date
- The right to request that your personal data is erased where it is no longer necessary to retain such data
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller (known as ‘the right to data portability’), where applicable i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means)
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing
- The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests or in performance of a task in the public interest/exercise of official authority; direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact us.
No fee required – with some exceptions
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
We may update this policy from time to time, especially where specified data processors change or we collect new or other information. Updates will be made to this policy, published on the website, and you can check the notice date here. We will notify you of any changes which materially affect our relationship with you and how we treat or process your data.
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.
11. QUERIES, REQUESTS OR CONCERNS – HOW TO CONTACT US
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact us on firstname.lastname@example.org or by post at always possible ltd, 483 Green Lanes, London, N13 4BS. The person responsible for data protection is Richard Freeman.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031 231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.