always possible Privacy Policy

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.

Data controller

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 data@alwayspossible.co.uk 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.

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.

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).

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.

Marketing

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:

 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. 

Opting out

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.

Cookies

A cookie is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser. You can find out more about the use of cookies on http://www.allaboutcookies.org/. We use cookies to identify you when you visit the Websites and to keep track of your browsing patterns and build up a demographic profile. We also use cookies to analyse who has seen which of the pages on the Websites and to determine the most popular areas of the Websites so that we can improve and develop them.

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.

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.

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.

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.

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.

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.

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.

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 data@alwayspossible.co.uk 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.