Guideposts understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of Our Site;|
|“Cookie”||means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;|
|“Our Site”||means this website, www.herefirst.org.uk|
|“UK and EU Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and|
|“We/Us/Our”||means Guideposts Trust Limited (‘Guideposts’), a company registered in England and Wales under company number 1282361, whose registered address is Willow Tree House, Two Rivers, Station Lane, Witney, Oxfordshire, OX28 4BH and whose main trading address is Willow Tree House, Two Rivers, Station Lane, Witney, Oxfordshire, OX28 4BH.|
2. Information About Us
2.1. Our Site, www.herefirst.org.uk, is owned and operated by Guideposts Trust Ltd, a company registered in England and Wales under company number 1282361, whose registered address is Willow Tree House, Two Rivers, Station Lane, Witney, Oxfordshire, OX28 4BH and whose main trading address is Willow Tree House, Two Rivers, Station Lane, Witney, Oxfordshire, OX28 4BH.
3. Scope – What Does This Policy Cover?
4. What Data Do We Collect?
4.1.2 Date of birth
4.1.5 Contact Details and contact preferences
4.1.6 IP address (automatically collected)
4.1.7 Information about your situation that could help us personalise the service we offer, such as whether you are in need of support or care for someone else, and what conditions you have/the person you care for has.
4.1.8 Working status
4.1.9 Web browser type and version (automatically collected)
4.1.10 Operating system (automatically collected)
4.1.11 A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected)
4.2 We do not store credit card details nor do we share customer details with any third parties.
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security see section 6, below.
5.2 We use your data to provide the best possible services to you. This includes:
5.2.1 Providing and managing your Account
5.2.2 Providing and managing your access to Our Site
5.2.3 Personalising and tailoring your experience on Our Site
5.2.4 Supplying Our services to you
5.2.5 Personalising and tailoring Our services for you
5.2.6 Responding to communications from you
5.2.7 Supplying you with service emails and any newsletters that you have subscribed to.
5.2.8 Market research
5.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience
5.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email or telephone with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
6. How and Where Do We Store Your Data?
6.1 We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it.
6.2 Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).
6.3 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
6.4 Steps We take to secure and protect your data include:
6.4.1 All personal data is encrypted on the Oracle Service Cloud system
6.4.2 All Guideposts staff and sub-contractors have received mandatory data protection training
6.4.3 All Guideposts staff and sub-contractors require a login to access any personal data
6.5 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
7.1 We may sometimes contract with third parties to supply services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We do not store credit card details nor do we share customer details with any third parties.
7.2 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.3 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
8.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes.
9. How Can You Control Your Data?
9.1 When you submit information via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and in our “Manage E-mail Preferences” page).
9.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10. Your Right to Withhold Information
- You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data in order to log in as an individual member of HERE.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held) on payment of a small fee which will not exceed £10. Please contact Us for more details at firstname.lastname@example.org, or using the contact details below in section 13.
12. What Cookies Do We Use and What For?
12.2 All Cookies used by and on Our Site are used in accordance with current UK and EU Cookie Law.
12.3 Before any Cookies are placed on your computer or device, subject to section 12.4 and section 12.7, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended
12.4 Certain features of Our Site depend on Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 12.5. Your consent will not be sought to place these Cookies. You may still block these cookies by changing your internet browser’s settings as detailed below in section 12.9, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
12.5 The following first party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|cp_session||Store session specific user data including the following:· session ID· answers viewed· number of searches· previously viewed answers· previous searches· previously seen e-mail· last activity· login type – pta/oauth||Yes|
|cp_profile||User profile token so that the server can identify a user||Yes|
|cp_login_start||Temporary cookie to check if cookies are enabled||Yes|
|rnw_survery_login||Keep track of the last page that a user has submitted in a survey. If the user closes their browser and later clicks the survey link they will be taken to the page where they left off.||Yes|
|survey_submit_cookie||Prevents duplicate survey submits and question sessions from being created.||Yes|
12.6 Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the products and services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
12.7 The analytics service(s) used by Our Site use(s) Cookies to gather the required information. Google Analytics is a web analytics tool that helps website owners understand how visitors engage with their website. Google Analytics customers can view a variety of reports about how visitors interact with their website so that they can improve it.
Like many services, Google Analytics uses first-party cookies to track visitor interactions as in our case, where they are used to collect information about how visitors use our site. We then use the information to compile reports and to help us improve our site.
Cookies contain information that is transferred to your computer’s hard drive. These cookies are used to store information, such as the time that the current visit occurred, whether the visitor has been to the site before and what site referred the visitor to the web page.
Google Analytics collects information anonymously. It reports website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page.The analytics service(s) used by this Website use(s) the following Cookies:
|Name of Cookie||First / Third Party||Provider||Purpose|
|__utma Cookie||First||Google Analytics||A persistent cookie – remains on a computer, unless it expires or the cookie cache is cleared. It tracks visitors. Metrics associated with the Google __utma cookie include: first visit (unique visit), last visit (returning visit). This also includes Days and Visits to purchase calculations which afford ecommerce websites with data intelligence around purchasing sales funnels.|
|__utmb Cookie & __utmc Cookie||First||Google Analytics||These cookies work in tandem to calculate visit length. Google __utmb cookie demarks the exact arrival time, then Google __utmc registers the precise exit time of the user.Because __utmb counts entrance visits, it is a session cookie, and expires at the end of the session, e.g. when the user leaves the page. A timestamp of 30 minutes must pass before Google cookie __utmc expires. Given__utmc cannot tell if a browser or website session ends. Therefore, if no new page view is recorded in 30 minutes the cookie is expired.|
|__utmz Cookie||First||Google Analytics||Cookie __utmz monitors the HTTP Referrer and notes where a visitor arrived from, with the referrer siloed into type (Search engine (organic or cpc), direct, social and unaccounted). From the HTTP Referrer the __utmz Cookie also registers, what keyword generated the visit plus geolocation data.This cookie lasts six months. In tracking terms this Cookie is perhaps the most important as it will tell you about your traffic and help with conversion information such as what source / medium / keyword to attribute for a Goal Conversion.|
|__utmv Cookie||First||Google Analytics||Google __utmv Cookie lasts “forever”. It is a persistant cookie. It is used for segmentation, data experimentation and the __utmv works hand in hand with the __utmz cookie to improve cookie targeting capabilities.|
12.8 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
12.9 You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
12.10 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13. Contacting Us