Work Better Innovations Community Interest Company
Privacy Policy
January 2022
[Next Review: January 2023]
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and customers; in this policy we explain how we will handle your personal data.
1.2 By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
1.3 Our website incorporates privacy controls which affect how we will process your personal data.
2. How your “personal data” is used
2.1 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.2 We may process your account data (“account data“). The account data may include your name, email address, telephone number, fax number, newsletter subscription preference and postal address. The account data may be processed for the purposes of operating our website, providing our business and/or community services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.3 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4 We may process information contained in any enquiry you submit to us regarding our services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you.
2.5 We may process information relating to transactions, including purchases of services, that you enter into with us (“transaction data“). The transaction data may include your contact details, select payment details and the transaction details. The transaction data may be processed for the purpose of supplying the services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
2.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.7 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.8 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.9 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.10 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3. Providing your personal data to others
3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.2 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. Retaining and deleting personal data
4.1 We will retain your personal data for a minimum period of 30 days following its provision.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We aim to review data annually and delete any non-active or non-useful (legitimately useful) personal profiles.
4.3 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on its necessity for the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
4.4 Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4.5 Our website and services are targeted at persons over the age of 16. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
5. Your rights
5.1 Right to access: You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. You can request a copy of the personal data we hold by contacting us. Please note that we may in return request copies of valid identification.
5.2 Right to rectification: You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
5.3 Right to erasure: In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
5.4 Right to restrict processing: In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
5.5 Right to object to processing: You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims. You have the right to object to our processing of your personal data for direct marketing purposes. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
5.6 Right to data portability: To the extent that the legal basis for our processing of your personal data is with consent or that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
5.7 Right to complain to a supervisory authority: If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the UK by submitting a complaint to the Information Commissioner’s Office, the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals (https://ico.org.uk/make-a-complaint/). You also may exercise any of your rights in relation to your personal data by written notice to us, in addition to complain to a supervisory authority.
5.8 Right to withdraw consent: To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6. International transfers of your personal data
6.1 We and our other group companies have offices and facilities in the United Kingdom. The European Commission has made an “adequacy decision” with respect to data protection laws of each of countries in the EEA. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from the Information Commissioner’s Office.
6.2 Web hosting for our website is done by Bluehost, which has data centres in the United States, and uses Secure Socket Layer (SSL certificates) as an encryption protocol as per industry practice.
7. Third party websites
7.1 Our website includes hyperlinks to, and details of, third party websites.
7.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
8.4 We use cookies for the following purposes:
a) authentication: we use cookies to identify you when you visit our website and as you navigate our website;
b) personalisation: we use cookies to store information about your preferences and to personalise our website for you;
c) analysis: we use cookies to help us to analyse the use and performance of our website and services; and
d) cookie consent: we use cookies to store your preferences in relation to the use of cookies more generally.
8.5 Our service providers use cookies and those cookies may be stored on your computer when you visit our website. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
8.6 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via the web browser your use. Blocking all cookies may limit your usability of many websites, including our website.
9. Update and amendments
9.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
9.2 We will review this privacy notice on an annual basis and may update this policy from time to time by publishing a new version on our website.
9.3 You should check this page occasionally to ensure you are happy with any changes to this policy.
9.4 We may notify you of changes to this policy by email or other means of communication.
10. Our details
10.1 This website is owned and operated by Work Better Innovations Community Interest Company, registered at the following address:
Innovation Space, Halpern House, 1-2 Hampshire Terrace, Portsmouth PO1 2QF, England.
10.2 You may exercise any of your rights in relation to your personal data by written notice to our Data Protection Officer, in addition to complain to a supervisory authority in Section 5. You may contact us by post, to the postal address given above; or using our website contact form, phone and email address, listed below:
Website: www.workbetterinnovations.com
Phone: +44 7984 222216
Email: hello@workbetterinnovations.com.
