1. How we collect personal information about you
2. What personal information do we use?
3.  How and why will we use your personal information?
4.  Lawful bases
5. Communications for marketing/ fundraising
6. Children’s personal information
7. How long do we keep your personal information?
8. Will we share your personal information?
9. Security/ storage of and access to your personal information
10. International Data Transfers
11. Exercising your Rights
12. Changes to this Policy
13. Links and third parties
14. How to contact us

a. When you give it to us directly.
For example, personal information that you submit through our website purchasing a product or using our contact details to communicate with us.

b. When we obtain it indirectly.
For example, your personal information may be shared with us by third parties including third party service providers, analytics providers and search information providers. To the extent we have not done so already, we will notify you when we receive personal information about you from them and tell you how and why we intend to use that personal information.

c. When it is available publicly
Your personal information may be available to us from external publicly available sources. For example, depending on your privacy settings for social media services, we may access information from those accounts or services, if for example you interacted with us via Facebook or Twitter.

d. When you visit our website

When you visit our website, we automatically collect the following types of personal information:

• Technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.
• Information about your visit to the websites, including the uniform resource locator (URL) clickstream to, through and from the website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.

This website uses cookies (small text files placed on your computer or device) but only insofar as they are required to allow you to navigate this site. We DO NOT use cookies to collect or process any personal data. However, you can choose to decline cookies if you prefer by modifying your browser settings. To find out more about cookies, including how to manage and delete them, please visit www.allaboutcookies.org.

In general, we may combine your personal information from these different sources set out in a-d above for the purposes set out in this Policy.

We may collect, store and otherwise process the following kinds of personal information:

• your name and contact details including postal address, telephone number, email address and, where applicable, social media identity;
• your position in an organisation, and information related to the work that you do there;
• your date of birth and gender;
• your financial information, such as bank details and/ or credit/ debit card details, account holder name, sort code and account number;
• your transaction history;
• personal information you provide to us to receive technical assistance or during customer service interactions;
• product performance data and details about you use our products and services;
• information about your computer/ mobile device and your visits to and use of this website, including, for example, your IP address and geographical location;
• personal descriptions and photographs;
• details of your qualifications/ experience;
• tax reference and national insurance numbers;

and/ or any other personal information which we obtain as per paragraph 1.

Do we process special categories of data?
The EU General Data Protection Regulation (“GDPR”) recognises certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health, ethnicity and actual or alleged criminal offences.

In certain situations, we may collect and/or use these special categories of data. We will only process these special categories of data if there is a valid reason for doing so and where the GDPR allows us to do so.

Your personal information, however provided to us, will be used for the purposes specified in this Policy. In particular, we may use your personal information:

• to provide you with services, products or information you have requested;
• to provide further information about our work, services or activities (where necessary, and only where you have provided your consent to receive such information);
• to update you on the status of your orders/requests;
• to answer your questions/ requests and communicate with you in general;
• to manage relationships with our partners and service providers;
• to allow you to register products or services you purchase;
• to manage your subscriptions;
• to provide you with technical and customer support;
• to analyse and improve our work, services, activities, products or information (including our website), or for our internal records;
• to run/administer our operations (including our website), keep them safe and secure and ensure that content is presented in the most effective manner for you and for your device;
• to audit and/ or administer our accounts
• to administer your employment with us;
• to process your application for employment with us
• to satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/ or law enforcement bodies with whom we may work (for example requirements relating to the payment of tax or anti-money laundering);
• for the prevention of fraud or misuse of services; and/or
• for the establishment, defence and/ or enforcement of legal claims.

The GDPR requires us to rely on one or more lawful bases to use your personal information. We consider the grounds listed below to be relevant:

• Where you have provided your consent for us to use your personal information in a certain way (for example, we may ask for your consent to use your personal information to send you promotional material by certain electronic channels).
• Where necessary so that we can comply with a legal obligation to which we are subject (for example, where we are obliged to share your personal information with regulatory bodies which govern our work and services).
• Where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract (for example, to provide you with products that you have purchased from us).
• Where there is a legitimate interest in us doing so.

The GDPR allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights as an individual).

In broad terms, our “legitimate interests” means the interests of running Gordon Associates as an IT software developer; for example communicating with you so that we can tailor our products to your requirements.

When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and on your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).

We may use your contact details to provide you with information about our work, events, services and/ or products which we consider may be of interest to you (for example, about products you previously used, or updates about new products we have developed which are relevant to you or your organisation).

Where we do this via email, SMS or telephone, we will not do so without your prior consent (unless allowed to do so via applicable law).

Where you have provided us with your consent previously but no longer wish to be contacted by us, please let us know at marketing@GordonAssociates.co.uk.

You can opt out of receiving emails from us at any time by clicking the “unsubscribe” link at the bottom of any marketing emails we send you.

When we process children’s personal information, where required we will not do so without their consent or, where required, the consent of a parent/ guardian. We will always have in place appropriate safeguards to ensure that children’s personal information is handled with due care

In general, unless still required in connection with the purpose(s) for which it was collected and/or processed, we remove your personal information from our records six years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure (please see Section 11 below), we will remove it from our records at the relevant time .

If you request to receive no further contact from us, we will keep some basic information about you on our suppression list in order to comply with your request and avoid sending you unwanted materials in the future.

We do not share, sell or rent your personal information to third parties for marketing purposes. However, in general we may disclose your personal information to selected third parties in order to achieve the purposes set out in this Policy.

These parties may include (but are not limited to ):

• suppliers and sub-contractors for the performance of any contract we enter into with them, for example IT service providers such as website hosts or cloud storage providers;
• our partner organisations;
• our customers;
• banks;
• financial companies that process payments on our behalf;
• social media platforms;
• digital advertisers or advertising networks
• professional service providers such as accountants and lawyers;
• parties assisting us with research to monitor the impact/effectiveness of our services; and
• regulatory authorities, such as tax authorities.

In particular, we reserve the right to disclose your personal information to third parties:

• in the event that we sell or buy any business or assets, in which case we will disclose your personal information to the (prospective) seller or buyer of such business or assets;
• if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;
• if we are under any legal or regulatory duty to do so; and/or
• to protect the rights, property or safety of Gordon Associates, its personnel, users, visitors or others.

Gordon Associates is committed to keeping your personal information safe and secure and we have appropriate and proportionate security policies and organisational and technical measures in place to help protect your information.
Your personal information is only accessible by appropriately trained staff, volunteers and contractors, and stored on secure servers which have features to prevent unauthorised access.

Given that we are a UK-based organisation, we will normally only transfer your personal information within the UK or European Economic Area (“EEA”), where all countries have the same level of data protection law as under the GDPR.

However, because we may use agencies and/or suppliers to process personal information on our behalf, it is possible that personal information we collect from you will be transferred to and stored in a location outside the EEA).

Please note that some countries outside of the EEA have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals. Where your personal information is transferred, stored and/or otherwise processed outside the EEA in a country that does not offer an equivalent standard of protection to the EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards (such as by entering into standard contractual clauses authorised by the European Commission) designed to protect your personal information and to ensure that your personal information is treated securely and in accordance with this Policy. If you have any questions about the transfer of your personal information, please contact us using the details below.

Unfortunately, no transmission of your personal information over the internet can be guaranteed to be 100% secure – however, once we have received your personal information, we will use strict procedures and security features to try and prevent unauthorised access.

Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for marketing or fundraising purposes or to unsubscribe from our email list at any time. You also have the following rights:

• Right of access – you can write to us to ask for confirmation of what personal information we hold on you and to request a copy of that personal information. Provided we are satisfied that you are entitled to see the personal information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exemptions that apply.
• Right of erasure – at your request we will delete your personal information from our records as far as we are required to do so. In many cases we would propose to suppress further communications with you, rather than delete it.
• Right of rectification – if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated. You can also ask us to check the personal information we hold about you if you are unsure whether it is accurate/up to date.
• Right to restrict processing – you have the right to ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage.
• Right to object – you have the right to object to processing where we are (i) processing your personal information on the basis of the legitimate interests basis (see paragraph 4), (ii) using your personal information for direct marketing or (iii) using your information for statistical purposes.
• Right to data portability – to the extent required by the GDPR, where we are processing your personal information (that you have provided to us) either (i) by relying on your consent or (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contact, and in either case we are processing using automated means (i.e. with no human involvement), you may ask us to provide the personal information to you – or another service provider – in a machine-readable format.

Rights related to automated decision-making – you have the right not to be subject to a decision based solely on automated processing of your personal information which produces legal or similarly significant effects on you, unless such a decision (i) is necessary to enter into/perform a contract between you and us/another organisation; (ii) is authorised by EU or Member State law to which we are subject (as long as that law offers you sufficient protection); or (iii) is based on your explicit consent.Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you contact us using the details in paragraph 14 below.

We encourage you to raise any concerns or complaints you have about our data processing by contacting us using the details provided in paragraph 14 below.  You are further entitled to make a complaint to the Information Commissioner’s Office – www.ico.org.uk. For further information on how to exercise this right, please contact us using the details below

We may update this Policy from time to time. We will notify you of significant changes by contacting you directly where reasonably possible for us to do so and by placing an update Policy on our website. This Policy was last updated on 24 May 2018.

We link our website directly to other sites. This Policy does not cover external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any external websites you visit via links on our website.

Please let us know if you have any questions or concerns about this Policy or about the way in which we process your personal information by contacting us at the channels below. Please ask for / mark messages for the attention of our Information Security Officer, Gordon Harrison.

Email: gordon@gordonassociates.co.uk

Telephone: 01242 529820

Post: Gordon Associates, Suite G1, Montpellier House, Montpellier Drive, Cheltenham, Glos. GL50 1TY