WhenIsGood : Privacy

Privacy and Data Protection Policy - whenisgood.net

General
1. The team at WhenIsGood.net ("we" or "us") take the privacy of your information very seriously. Our Privacy and Data Protection Policy is designed to tell you, the user of our availability and booking service ("Service") about our practices regarding the collection, use and disclosure of personal and other information about you or your business that may be provided via our website (https://whenisgood.net/) or app (together the "Site") or collected through other means such as an online form, email or telephone communication.
2. This policy applies to personal data we process in relation to our users, whether they are using the Service as a registered account holder or not (together the "members") or otherwise simply visiting the Site, and any third party agents or suppliers whose data we process, but does not apply to information we hold in relation to our staff or contractors. In this policy "you" refers to any individual whose personal data we hold or process. This privacy policy is governed by the EU General Data Protection Regulation (the "GDPR"), the Data Protection Act 2018 and any other applicable data or privacy legislation.
3. Important Note: If you are using our Service to respond to an event invitation with our member (referred to for convenience as an "attendee") please note that the member is the Controller and we are Processor of the personal data relating to you, the attendee. We cannot control and we are not responsible for the use made of that personal data by the relevant user or account holder. In these circumstances where we are acting as Processor, our standard Data Processing Agreement ("DPA") will govern the terms under which we collect and process the relevant personal data. You, the relevant member can request a signed copy of our DPA. The DPA includes details of the scope, nature and purpose of the processing of data, the duration of the processing, the types of personal data processed, the data subjects involved and those contract terms which are required by Article 28 of the GDPR. The DPA is incorporated into each contract between us and you, the relevant member, but if you would like a separate, signed DPA between you and us then please contact us at team@whenisgood.net.
Our Policy
1. We aim to limit our interaction with your data wherever possible. We have a general policy relating to access to your data. We will generally seek only to access that data which is necessary in accordance with the privileges you have granted to the system. Automated processes may scan your data, but only for an explicit purpose to do with the management of your bookings or delivery of other services. When working with data that was originally collected by us, our processes may need to scan and manipulate the information in order to deliver our service to you.
Personal Data we collect & how we process this data
1. We may collect and process the following personal data about you:
  1. Contact information we collect from you as a member, whether about you or your employees (for example names, telephone numbers and email addresses provided to us by you or your employer) (Contact Information)
    We process this information in order to provide the Service to you (and your employees, as the case may be) as well as to notify you of various things (for instance about changes to the Service), on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our Service to you (and your employees, as the case may be).
  2. Log-in details and information you provide as an account holder when you register with the Service (Log-In Information)
    We process this information in order to provide the Service to you (and your employees, as the case may be) on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing our Service to you (and your employees, as the case may be).
  3. any information which is contained in any third party service or calendar account (e.g. Google Calendar account) which you have linked with your whenisgood.net account (Calendar Information) (but please note our general policy in paragraph 2.1 above)
    We process this information in order to communicate availability data from a third party calendar account (e.g. Google Calendar) which is linked with your whenisgood.net account on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing the Service to you.
  4. a record of any correspondence or communication between you and us including with respect to an enquiry or otherwise if you report a problem or complain to us (Correspondence Information)
    We process this information as part of monitoring our relationship with you and providing services to you on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing the Service to you.
  5. a record of and information relating to event creations and responses made through the Service and other interactions with the Service or the Site (Event Information)
    We process this information to communicate data about the free and busy times of each attendee's responses in the administration of bookings, on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing the Service to you.
  6. Financial information which we hold in the context of providing services to you as a premium account holder (Financial Information) such as billing and banking details.
    We process this information on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing the Service to you.
  7. Contact information which we hold because you are a third party relevant to the services we provide to our users (you may for example be a payment processor) (Third Party Contact Information).
    We process this information as part of the provision of our Service to our users or or members on the basis of the performance of our contract with you or on the basis of our legitimate interest in providing the Service to our users or members.
  8. Cookie Information. A cookie is a small text file which asks permission to be placed on your computer's hard drive or mobile device. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site(Cookie Information).
    Where applicable and necessary, we process Cookie Information on the basis that you have consented to this in order to improve or communicate with you about our services and/or to customise the website according to your personal interests.
  9. Marketing information. We may hold information about you in order to provide information about our services. This may include names, job titles, email addresses, phone numbers, addresses, and other information (Marketing Information).
    We process this information in order to improve or customise our services, communicate with you about our services or for market research purposes, on the basis of our legitimate interests in communicating with you about our services or on the basis that you have consented to receiving the information.
2. We generally collect information from you directly however in certain circumstances, we may also collect it indirectly from a third party. For instance, information may also be gathered through the Site without you actively providing it, through the use of various technologies and methods such as Internet Protocol (IP) addresses and cookies.
3. If we do obtain your personal data from a third party your privacy rights under this policy are not affected and you are still able to exercise the rights contained within this privacy policy.
4. You do not have to supply any personal information to us but our Service may not be operable in practice without providing such data to us.
Data Retention
1. Our current data retention policy is to delete or destroy (to the extent we are able to) personal data after the following periods:
  1. Following an enquiry with us, we will remove your Contact Information and Correspondence Information from our CRM system after a period of 1 year unless you subsequently enter into a contract with us.
  2. In respect of records relating to a contract with us - 7 years from either the end of the contract or the date you last used our services (whichever is later).
  3. In respect of Event Information â 1 year from the end of the relevant event.
  4. In respect of records relevant for tax purposes â 8 years from the end of the tax year to which the record relates
  5. In respect of Cookie Information â such data is removed after 2 year. After such period, only aggregated data (from which all personal data has been removed) is stored by us.
  6. In respect of Marketing Information â 3 years from the last date on which you have interacted with us.
2. For any category of personal data not specifically defined in this policy, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data. The retention periods stated in this policy can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
3. We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or securely delete this data as may be required.
4. If you wish to request that data we hold about you is amended or deleted, please see below for your privacy rights.
Sharing your information
1. We do not disclose any information you provide to any third parties other than as follows:
  1. We may work with other professionals and providers in providing and delivering our services to you - this may include a CRM or website management provider. For instance,;
  2. if you are a member we will share information contained in any content created by you with anyone who is seeking to make a response to an event using the Service. In addition, personal data may be sourced from a third party calendar account (e.g. Google Calendar account) which is linked with your account and is shared with anyone who is seeking to make a response to an event using the Service;
  3. if you are an attendee who is responding to an event we will supply any information you provide to us via the Service to the member who circulated the event details to you;
  4. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
  5. in order to enforce any terms and conditions or agreements for our Service that may apply;
  6. we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
  7. to protect the rights, property, or safety of WhenIsGood.net, our members, or any other third parties. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  8. We may disclose information to our group companies.
2. Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so.
Cookies and IP Address
1. We use cookies to help provide you with the best experience whilst using our service. The cookies we use are split between the following categories:
  1. Strictly necessary cookies - which are an essential part of our service and affect the way you can use our site (e.g. security & authentication)
  2. Performance cookies - which are used for analytics (e.g. understanding usage on our website)
  3. Functionality cookies - which collect information about your device to help you customize our service (e.g. remembering your username, language, time zone settings or accessing inline help)
  4. On your first visit to our site from your browser we will display a notice to notify you that we are using cookies but we will not load any cookies, except for Strictly Necessary Cookies, until you have provided your consent by clicking the "Accept" button. If you click the "Accept" button on our cookies notice, Performance and Functionality cookies will also be loaded.
2. Below is a list of the cookies currently set by us:
  1. JSESSIONID - simple session tracking
  2. wg_sesh - simple session tracking
  3. wg_access - user's preference for accessibility : rich or simple html view
  4. utm* - standard Google Analytics tracking
3. As well as cookies that are set by domains we control (first-party cookies), you may also see cookies set by a third party (third-party cookies). These are set when you interact with certain parts of our service and are used by these third-party services to understand your preferences and sometimes tailor content they show you.
4. Refusing Cookies You can change the way your browser handles cookies if you wish. You could accept or reject them by default or be notified when a website is trying to set or update cookie. Exactly how you disable cookies depends on the browser or device you are using. The help feature on most browsers will tell you how you how you can manage and or disable cookies. If you disable cookies on your browser, certain features or parts of our service may not function correctly or will have a degraded experience.
5. IP Address An Internet Protocol (IP) address is a number assigned to your computer by your Internet Service Provider (ISP), so you can access the Internet. We may use your IP address to diagnose problems with our server, report aggregate information, and determine the fastest route for your computer to use in connecting to our service, and to administer and improve the online service.
Security
1. We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
  1. protecting our servers by both hardware and software firewalls;
  2. locating our data processing storage facilities in secure locations;
  3. encrypting all data stored on our server with an industry standard encryption method that encrypts the data between your computer and our server so that in the event of your network being insecure no data is passed in a format that could easily be deciphered;
  4. when necessary, disposing of or deleting your data so it is done so securely;
  5. regularly backing up and encrypting all data we hold.
2. We will ensure that our staff are aware of their privacy and data security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and data security obligations.
  This policy and our procedures for handling personal data will be reviewed as necessary.
Your privacy rights
1. With respect to your personal data, you have:
  1. The right to be informed - a right to know about our personal data protection and processing activities, details of which are contained in this policy
  2. The right to access - the right to request a copy of any personal data that we have about you
  3. The right to rectification - the right to request a correction of any errors in or update of the personal data that we have about you
  4. The right to erasure (the 'right to be forgotten') - the right to request that your personal data is deleted from our records
  5. The right to restrict processing - the right to request that we no longer process your personal data in certain ways, whilst not requiring us to the delete the same data
  6. The right to object to processing - the right to request that your personal data will not be processed
  7. The right to data portability - the right to request that your personal data be transferred or exported to another organisation
  8. The right to withdraw consent - the right to withdraw any permission you have given us to process your personal data
  9. Rights in relation to automated decision making and profiling - the right not to be subject to automated decision-making (including profiling) when those decisions have a legal (or similarly significant effect) on you
  10. Rights in relation to direct marketing - the right to request that your personal data will not be used to contact you for direct marketing purposes
2. All SARs and other requests or notifications in respect of your above rights must be sent to us in writing via our contact page at at https://whenisgood.net/ContactUs
3. We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
Other websites
1. Our Site may contain links and references to other websites. Please be aware that this Privacy Policy does not apply to those websites.
2. We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via the Site and/or any other service that is operated by us. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
3. In addition, if you came to this App or Site via a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
Data breaches
1. If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to our data protection manager or officer (if an officer has been appointed) and the ICO (as necessary).
2. If a breach is likely to result in a high risk to your data rights and freedoms, we will notify you as soon as possible.
Transferring your information outside of the EEA
1. We will not transfer your personal data in a systematic way outside of the European Economic Area or UK (together the "EEA") but there may be circumstances in which certain personal data is transferred outside of the EEA, in particular:
  1. From time to time, some of our data processors (including third party payment processors or server providers), may be based outside of the EEA. In that case, we will ensure we have an agreement in place with such processors to provide adequate safeguards and a copy of such safeguards will be available on request.
  2. If you use our services while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with our services or communicate with you.
  3. We may communicate with individuals or organisations outside of the EEA in providing our services. Those communications may include personal data (such as contact information).
  4. From time to time your information may be stored in devices which are used by our staff outside of the EEA (but staff will be subject to our cyber-security policies).
  5. If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and we will be responsible for ensuring your privacy rights continue to be protected as outlined in this policy.
Notification of changes to our Privacy Policy
1. We will post details of any changes to our Privacy Policy on the Site to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.
Contact us
1. If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your personal information, you can do so by way of our contact page at https://whenisgood.net/ContactUs
Complaints
1. If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the Information Commissioner's Office by visiting http://www.ico.org.uk/ for further assistance.