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PRIVACY POLICY

Introduction


Welcome to the PLATF9RM privacy policy (‘Policy’).

We respect your privacy and are committed to protecting your personal data. This Policy will inform you as to how we look after your personal data, including when you visit our website (regardless of where you visit it from), or when you use our services or otherwise engage with us, and tells you about your privacy rights and how the law protects you.

This Policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Policy.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE Data We Collect About You
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. GLOSSARY
  11. COOKIE POLICY


 

1. Important Information and Who We Are

Purpose Of This Policy

PLATF9RM

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Policy together with any other privacy notice or Data Processing Agreement 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 Policy supplements the other notices and is not intended to override them.


Controller


Platform Nine Limited (Company Number 10202637) is the controller and responsible for this website and is responsible for your personal data (collectively referred to as “PLATF9RM”, “we”, “us” or “our” in this Policy).

If you have any questions, including any requests to exercise your legal rights, please contact our Community Lead using the details set out below.


Contact Details


Our full details are:
Platform Nine Limited, 28 Clifton Road, Brighton, United Kingdom, BN1 3HN


Email: admin@platf9rm.com


Telephone: 01273 437090


Changes To The Policy And Your Duty To Inform Us Of Changes


This version was last updated in May 2018 and may be subject to further revisions.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.


Third-Party Links


This website 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 website, we encourage you to read the privacy notice of every website you visit.

 

2. The Data We Collect About You

 

  • Identity Data includes: first name, last name, username or similar identifier, marital status, title, date of birth and gender, passport or ID number, photos, video or other images.
  • Contact Data includes: billing address, home address, email address and telephone numbers, and any social media accounts used to contact us or register on our systems (including PLATF9RM account ).
  • Financial Data includes: bank account and payment gateway (i.e. Stripe or PayPal) or card details.
  • Transaction Data includes: details about payments to and from you and details of services or events you have registered for from us or a third party via our own or a third party website.
  • Technical Data includes: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes: any username and password to access our systems (including PLATF9RM account), or orders or event registrations made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes: information about how you use our website, products and services.
  • Marketing and Communications Data includes: your preferences in receiving marketing from us and any third parties (i.e. event organisers) and your communication preferences, including our use of photos, videos or other images in which you may feature.


We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:


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.


We do not collect any Special Categories of Personal Data about you (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 Fail To Provide Personal Data


Where we need to collect personal data by law, or under the terms of a contract we have with you, or which is a condition of an event registration or other service, 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 (or to provide you with services). In this case, we may have to cancel a registration or service you have with us but we will always aim to notify you if this is the case at the time.

3. How is your personal data collected?


– Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms on our websites or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:
– Book a tour of our locations;
– Register as a member;
– Register as a participant for an event
– Create an account on our website or on one of our systems (PLATF9RM Account).
– Request marketing to be sent to you;
– Enter a competition, promotion or survey;
– Make a general enquiry about our services; or give us feedback.

Automated technologies or interactions. As you interact with our website or social media accounts, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:

(a) analytics providers such as Google inside the EU;

(b) advertising networks, such as GoogleAds, Twitter, Instagram, LinkedIn and Facebook, based inside or outside the EU; and

(c) search information providers, such as Google, based inside the EU.
Contact, Financial and Transaction Data from providers of technical, payment and delivery services, based inside or outside the EU and HM Revenue & Customs (HMRC).

Technology providers we use, including client relationship, marketing and other hosting and communications providers (i.e. MailChimp), inside or outside the EU.

Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based in the UK.

CCTV images from building owners and location managers.

 

4. How We Use Your Personal Data


– To process your location tour booking, registration as a member or registration for an event at one of our locations.
– Where we need to perform the contract we are about to enter into or have entered into with you, or in relation to an event organiser that we have entered into a contract with.
– For use with technology providers for the administration of our business, including client relationship, financial, marketing and other hosting and communications providers (i.e. Xero or MailChimp), inside or outside the EU.
– Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
– Where we need to comply with a legal or regulatory obligation.

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending you marketing or third party direct marketing communications via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us or by clicking ‘unsubscribe’ in any communication you receive from us.

Purposes For Which We Will Use Your Personal Data

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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.

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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 have established the following personal data control mechanisms:

Surveys & Promotional Offers From Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

We may send you event reminders close to the date of an event or service you have registered for, or information on events or services similar to those you have previously registered for or other communications we are obliged to send under a legal or contractual obligation.

You may receive marketing communications from us if you have expressly requested information from us about our services, other events or services, or made an enquiry, or if you provided us with your details when you entered a competition or registered for a promotion. We will not however send you generic marketing about us unless you have expressly consented to receive it.



Third Party Marketing

We will seek your express opt-in consent before we share your personal data with any company outside of the PLATF9RM group of companies for marketing purposes.



Opt Out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website or your PLATF9RM account and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out or unsubscribe’ links in any marketing message sent to you or by Contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience, event or other transaction, or where we need to keep your contact details or make contact with you for contractual performance or legitimate interest purposes, or compliance with a legal obligation.



Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy.

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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will 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. Disclosures Of Your Personal Data



We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

– Internal Third Parties as set out in the Glossary or elsewhere in this Policy.
– External Third Parties as set out in the Glossary or elsewhere in this Policy.
– Specific third parties listed in the Glossary or elsewhere in this Policy.
– Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

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



We do not transfer your personal data outside the European Economic Area (EEA).

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. We seek to use third party technology providers that are ISO27001 certified or equivalent (SOC II) where practical.

8. Data Retention



How Long Will You Use My Personal Data For?

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 determine 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 and employees (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers or employees for tax and legal liability purpose, but we also keep this information to make it easier for customers to make new, follow-on or repeat service orders. We will seek to renew consent for marketing communications every two years.

In some circumstances you can ask us to delete your data: see Request erasure 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



Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

– Request access to your personal data.
– Request correction of your personal data.
– Request erasure of your personal data.
– Object to processing of your personal data.
– Request restriction of processing your personal data.
– Request transfer of your personal data.
– Right to withdraw consent.
If you wish to exercise any of the rights set out above, please Contact us.

No Fee Usually Required

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 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. Glossary



Lawful Basis

Consent means the unambiguous approval to use personal data in a specific way, it must involve a clear affirmative action (an opt-in). In relation to the use of Special Personal Data, the consent must be given expressly in relation to this use. We seek consent in relation to marketing permissions and in relation to our own employees or sub-contractors.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.

Performance of Contract 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.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

Internal Third Parties

Other companies in the PLATF9RM group acting as joint controllers or processors and which provide IT and system administration services and undertake leadership reporting.

External Third Parties

– Service providers acting as processors based in and outside the EU who provide IT and system administration services (i.e. MailChimp).
– Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the EU who provide consultancy, banking, legal, insurance and accounting services to us.
– HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom or EU who require reporting of processing activities in certain circumstances.

Your Legal Rights

You have the right to:

– Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
– Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
– Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
– Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
– Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
– Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
– Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

11. Cookie Policy

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Strictly Necessary Cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Analytical/Performance Cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality Cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting Cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site

[Policy End]

1. Cookie Policy

 

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Platform Nine Ltd has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, in the coming year we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

Responsibility for the policy

Platform Nine LTD has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Platform Nine LTD has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Managing Director.

Compliance with the policy

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control.

You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your line manager OR a company Director as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your line manager or company Director OR report it in accordance with our Whistleblowing Policy as soon as possible.

You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your line manager or company Director.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.

If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current employee handbook.

This Modern (Anti) Slavery Policy and Statement is intended for businesses in all countries, especially the United Kingdom; and was brought to you by Rushax.

Communication & awareness of this policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and you. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.