Privacy Policy - 30 Day Drink Less Programme
Welcome to the Alcohol Health Network’s Drink Less Programme privacy notice.
Alcohol Health Network CIC respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you use our service (regardless of where you use it) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy [here].
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW IS YOUR PERSONAL DATA COLLECTED?
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- GLOSSARY
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Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Alcohol Health Network collects and processes your personal data through your use of our service, including any data you may provide through this website when you register for our service.
This website is not intended for children and we do not knowingly collect data relating to children.
Controller
We are Alcohol Health Network CIC. We are the controller and responsible for your personal data in relation to the provision of our service.
Contact details
If you have any questions about this privacy notice or our privacy practices, please contact us in the following ways:
Full name of legal entity: Alcohol Health Network CIC
Email address: [email protected]
Postal address: 465A Hornsey Road, Unit 4, First Floor, London N19 4DR
Telephone number: +44 (0)20 315 12420
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. Historic versions can be obtained by contacting us.
Other users
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.
We deliver our service using a third party learning platform called Kajabi. Kajabi acts as a data processor for us – that is, it processes your personal data for the purposes of providing us with a service.
When you sign up to our service, Kajabi will process the email address you provide us, along with the details of your subscription, and other information it collects through your interactions with this website. As well as using it to power our service, Kajabi may also use that information for its own purposes, including troubleshooting and support, improving its services, and protecting against fraud. Kajabi will in those cases process your data as a ‘data controller’, not as our data processor. Kajabi’s own privacy policy at https://kajabi.com/policies/privacy applies to Kajabi’s use of your information for its own purposes.
This privacy notice you are now reading only concerns the processing for which we are the data controller. If you have any questions regarding Kajabi’s use of personal data, please contact Kajabi as set out in their privacy policy.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data which is limited to your email address, first name and a password.
- Contact Data which is limited to your email address.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- 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 your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of our service. 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 ask you to provide any Special Categories of Personal Data (such as health data or ethnic origin) and we do not collect any from you. All the information you input into our ‘Drink Checker’ site is anonymised and we have no way of associating it with your email address or any other information we hold about you. Nor do we collect any information about criminal convictions and offences. (Obviously, we record the fact that you have registered for our service, but we do not consider that this alone can be seen as data concerning your health.)
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- register for our services;
- request marketing to be sent to you;
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our service, we will 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. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie notice for further details.
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:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where we have your consent.
- 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 obligation.
Purposes for which we will use your personal data
The legal bases on which we rely in order to process your personal data are as follows. 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.
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: 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 obligation: processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Consent: your affirmative specific, informed consent. We use this as the basis for sending you emails promoting our services. You have the right to withdraw consent to marketing at any time by contacting us by email at [email protected].
We have set out below, the purposes for which we will use your personal data.
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To register you as a new customer |
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To process and deliver your order for our service including: (a) Manage payments, fees and charges (b) Setting up your account for our service (c) Collect and recover money owed to us |
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To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey (c) Responding to comments, queries or complaints |
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To administer and protect our business (including bringing and defending legal claims) and this website (including fraud prevention, security, troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
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To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising or promotional emails we serve to you |
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To use data analytics to improve our website, products/services, marketing, customer relationships and experiences |
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To make suggestions and recommendations to you about goods or services that may be of interest to you |
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).
You will only receive marketing communications from us if you have consented to it.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us to stop sending you marketing messages at any time by contacting us at [email protected] at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service purchase, service experience or other transactions.
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 our [link - cookie notice].
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.
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Kajabi will have access to your data in the course of powering our services. If you consent to it, they will also process it for their own purposes in accordance with their own privacy policy at https://kajabi.com/policies/privacy.
- Other service providers such as Google, who host our data and administer our business. We require all our third party service providers to respect the security of your personal data and to treat it in accordance with the law. Except where you have consented to our doing so, we do not allow our third-party service providers to use your personal data for their own purposes.
- Stripe, our payment service provider. Where you place an order for our service, in order to process your payment, we use Stripe, a third party payment processor. Your payment will be processed by Stripe, who collect, use and process your information, including payment information, in accordance with their privacy policies. You can access Stripe’s privacy policy at https://stripe.com/gb/privacy/.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- 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 privacy notice.
Some of our service providers process data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring the recipient signs up to a specific contract approved for use in the UK which give personal data similar protection to that which it has in the UK. Please contact us if you want further information on the contracts used by us when transferring your personal data out of the UK.
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.
How long will you use my personal data for?
By law we have to keep basic information about our customers for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
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 could 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 could take us longer than a month if your request is particularly complex or you have made a number of requests.
If you wish to exercise any of the rights set out below, please contact us at [email protected].
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:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- 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.
- 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.
