This is the privacy policy for Locality. We are a company limited by guarantee (number 2787912 ) and a registered charity (number 1036460) registered in the United Kingdom.

Our registered office is at 33 Corsham Street, London N1 6DR.

1. Purpose of the policy

1.1. This policy sets out how we will collect, process, store and use the information we hold about you.

1.2. We take seriously the protection of your privacy and confidentiality and we understand that you are entitled to know that your personal data will not be used for any unintended purpose and will not accidentally fall into the hands of a third party.

1.3. We undertake to preserve the confidentiality of all information you provide to us.

1.4. Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).

1.5. The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. This information can be found at www.knowyourprivacyrights.org

1.6. Except as set out below, we do not share, or sell, or disclose to a third party, any information personal information we collect.

2. The basis on which we process information about you

2.1. The law requires us to determine under which the defined bases we process different categories of your personal information, and to notify you of the basis for each category.

2.2. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

2.3. If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

3. Information we process because we have a contractual obligation with you

3.1. When you create an account on any of our websites, buy a product or service from us, apply for one of our grant or support programmes, or otherwise agree to our terms and conditions, a contract is formed between you and us.

3.2. In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.

3.3. We may use it in order to:

3.3.1. verify your identity for security purposes

3.3.2. provide you with our services

3.3.3. provide you with suggestions and advice on products, services and how to obtain the most from using our website

3.4. We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

3.5. Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

3.6. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

4. Information we process with your consent

4.1. Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.

4.2. Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to our use of cookies.

4.3. Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

4.4. Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

4.5. If you have given us explicit permission to do so, we may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful. This may include partners on our programmes.

4.6. We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

4.7. You may withdraw your consent at any time by instructing us info@locality.org.uk. However, if you do so, we may not be able to provide you with our services further.

5. Information we process because we have a legal obligation

5.1. We are subject to the law like everyone else. Sometimes, we must process your information in order to comply with a statutory obligation.

5.2. For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

5.3. This may include your personal information.

6. Information provided on the understanding that it will be shared with a third party

6.1. Our website allows you to post information with a view to that information being read, copied, downloaded, or used by other people. Examples include:

6.1.1. posting a message our forum

6.1.2. tagging an image

6.1.3. clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks

6.1.4. requesting a service from us where we use third party agencies to provide specialist advice or support

6.2. In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.

6.3. We do not specifically use this information except to allow it to be displayed or shared.

6.4. We do store it, and we reserve a right to use it in the future in any way we decide.

6.5. Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

6.6. Provided your request is reasonable and there is no legal basis for us to retain it, then we may agree to your request to delete personal information that you have posted. You can make a request by contacting us at info@locality.org.uk.

7. Complaints regarding content on our website

7.1. We attempt to moderate user generated content, but we are not always able to do so as soon as that content is published.

7.2. If you complain about any of the content on our website, we shall investigate your complaint.

7.3. If we feel it is justified or if we believe the law requires us to do so, we shall remove the content while we investigate.

7.4. Free speech is a fundamental right, so we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

7.5. If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

8. Information relating to your method of payment

8.1. Payment information (e.g. credit or debit card information) is never taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.

8.2. At the point of payment, you are transferred to a secure page on the website of our payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.

9. Information about your direct debit

9.1. When you agree to set up a direct debit arrangement, the information you give to us is passed to our own bank, Unity Trust, for processing according to our instructions. We keep a copy only for the duration of the direct debit arrangement.

9.2. We are registered under the direct debit guarantee scheme. This provides for the customer’s bank to refund disputed payments without question, pending further investigation. Direct debits can only be set up for payments to beneficiaries that are approved originators of direct debits. In order to be approved, these beneficiaries are subjected to careful vetting procedures. Once approved, they are required to give indemnity guarantees through their banks.

10. Job application and employment

10.1. If you send us information in connection with a job application, we may keep it for up to three years in case we decide to contact you at a later date.

10.2. If we employ you, we collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, we will keep your file for six years before destroying or deleting it.

11. Sending a message to our support team

11.1. When you contact us, whether by telephone, through our website or by e-mail, we may collect the data you have given to us in order to reply with the information you need.

11.2. We record your request and our reply in order to increase the efficiency and quality of our service to you. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

12. Complaining

12.1. When we receive a complaint, we record all the information you have given to us.

12.2. We use that information to resolve your complaint.

12.3. If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

12.4. We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

13. Use of information we collect through automated systems when you visit our website

13.1. Cookies

13.1.1. Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

13.1.2. Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

13.1.3. Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

13.1.4. Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

13.1.5. When you first visit our website, we ask you whether you wish us to use cookies. If you choose not to accept them, we shall not use them for your visit except to record that you have not consented to their use for any other purpose.

13.1.6. If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.

13.1.7. We use cookies in the following ways:

13.1.7.1. to track how you use our website

13.1.7.2. to record whether you have seen specific messages we display on our website

13.1.7.3. to keep you signed in our site

13.1.7.4. to record your answers to surveys and questionnaires on our site while you complete them

13.2. Personal identifiers from your browsing activity

13.2.1. Requests by your web browser to our servers for web pages and other content on our website are recorded.

13.2.2. We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

13.2.3. We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

13.2.4. If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

13.3. Our use of re-marketing

13.3.1. Re-marketing involves placing a cookie on your computer when you browse our website in order to be able to serve to you an advert for our products or services when you visit some other website.

13.3.2. We may use a third party to provide us with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for our products and services on other websites.

14. Access to your own information

14.1. Access to your personal information

14.1.1. You may obtain a copy of any information we hold about you by sending us a request at [email address].

14.1.2. After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

14.2. Removal of your information

14.2.1. If you wish us to remove personally identifiable information from our systems, you may contact us at info@locality.org.uk .

14.2.2. This may limit the service we can provide to you.

14.3. Verification of your information

14.3.1. When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

15. Encryption of data sent between us

15.1. We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

15.2. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

16. How you can complain

16.1. If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Our address is info@locality.org.uk

16.2. If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

16.3. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at ico.org.uk/concerns

17. Retention period for personal data

17.1. Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

17.1.1. to provide you with the services you have requested. This includes a record of your transactions with us in order to provide the best possible service should you contact us in the future;

17.1.2. to comply with other law, including for the period demanded by our tax authorities;

17.1.3. to comply with our funding agreements which usually expect us to keep records for up to seven years;

17.1.4. to support a claim or defence in court.

18. Review of this privacy policy

18.1. We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

18.2. If you have any question regarding our privacy policy, please contact us.

Locality’s privacy policy was reviewed on 5 March 2018.