In this Policy when we refer to Up the Garden Path “we”/“us”/“our” we mean Up the Garden Path Limited, a company registered in England and Wales (06320460).
We may revise this Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.
This Policy describes:
- The information that we collect
- How we use the information we collect
- How we share information with third parties
- Keeping your information and information security
- Your choices and rights
- How to contact us and other important information
The information that we collect and where we get it from
“Personal information” is any information that can be used to identify you or that we can link to you and which we have in our possession or control.
We will collect and process the following personal information about you:
Information that you provide to us
We will process personal information that you give to us including when you email us or contact us through various channels as follows:
- Signing up for services on our website: when you sign up for newsletters, events or enquire about our projects and products; or when you contact us with enquiries or respond to our communications, the personal information you provide may include your full name, title, telephone number, email address and information about your employer or your business.
- In connection with our provision of projects and products: As a partner or client, you provide us with personal information when you or the company you represent enquires about doing business together or entering into a contractual agreement with us. If you are not a direct business partner or client, then we may collect or receive your personal information because you are involved in one of our business matters.
- Recruitment application: when you apply for a role with us you may provide us with your full name, date of birth, nationality, education and qualification details, your gender, your CV, photograph, passport details, marital status, home address and home telephone number, mobile telephone number, utility bill and other details set out in your application
- Social media:we may contact you directly via LinkedIn, Twitter and other social media sites to obtain your email address. This is so that we can conduct a business discussion with you relating to our projects and products. We will not send you marketing mailings unless you have consented for us to do so.
Information we otherwise collect about you
How we use the information we collect
Depending on the purposes for which we have collected the information, we may do the following with your personal information;
- use it to engage in marketing and business development activity in relation to our projects and products. This may include sending you emails about our business activity and invitations to events.
- business referral to an interested party looking to use your business products or services.
- where you have applied for a position with us, to review and process your job application
- to comply with legal and regulatory obligations that we have to discharge
- record and monitor your use of our websites or our other online services for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports
- use it for our legitimate business interests, such as undertaking business research and analysis, managing the operation of our websites and our business
- use it to look into any complaints or queries you may have, and
- use it to prevent and respond to actual or potential fraud or illegal activities.
Grounds for using your personal information
We rely on the following legal grounds to process your personal information, namely:
- Consent– we may (but usually do not) need your consent to use your personal information. Where we rely on your consent, you can withdraw your consent by contacting us (see below).
- Performance of a contract– we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you.
- Legitimate interest– we may use your personal information for our legitimate interests, some examples of which are given above.
- Compliance with law or regulation– we may use your personal information as necessary to comply with applicable law/regulation.
How we share information with third parties
We share personal information with our data processors, such as accounting software platform, payroll bureau, online content management system, email platform, shared server, online file server, website provider and third parties providing business services to us. As a result, your personal information may be transferred to locations outside Europe as well as within it for the purposes described above.
Where we transfer your personal information outside Europe, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. This can be done in a number of different ways, for instance:
- the country to which we send the personal information may be approved by the European Commission
- the recipient may have signed a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal information, or
- where the recipient is located in the US, it may be a certified member of the EU-US Privacy Shield scheme.
In other circumstances, the law may permit us to otherwise transfer your personal information outside Europe. In all cases, however, any transfer of your personal information will be compliant with applicable data protection law.
Keeping your information and information security
How long we hold your personal information for will vary and will depend principally on:
- the purpose for which we are using your personal information – we will need to keep the information for as long as is necessary for the relevant purpose, and
- legal obligations – laws or regulation may set a minimum period for which we have to keep your personal information.
We will ensure that the personal information that we hold is subject to appropriate security measures.
Your choices and rights
You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below.
These rights may include:
- Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you.
- Requesting that we correct your personal information if it is inaccurate or incomplete.
- Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it.
- Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
- In some circumstances, receiving some personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit those information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.
- Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
- Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us. We can, on request, tell you which data protection authority is relevant to the processing of your personal information.
How to contact us and other important information
If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us:
- by email firstname.lastname@example.org