Your privacy is vitally important to us and we take it very seriously.
1. WHO ARE WE?
Here at Semble Network Limited (company number 05611771) (“Semble”, “we” or “us”), we’re keen to help people and organisations take forward their local community projects and ideas by providing a networking platform connecting projects and people. By enabling people to share resources and knowledge, Semble is a fun, interactive and value-added place to be. It’s important to be clear about how Semble handles personal data to make sure it works for all involved.
Semble’s registered office is located at 22 Wycombe End, Beaconsfield, Buckinghamshire, United Kingdom, HP9 1NB. Semble is a trading name of Semble Network Ltd (formerly Project Dirt Ltd).
Semble is a controller for the purpose of the Data Protection Act 2018 and the General Data Protection Regulation 2016/679. We are registered with the UK Information Commissioner’s Office as a controller with registration number: ZA288732 and details of our registration can be found here.
2.WHAT DOES THIS POLICY COVER
- the nature and sources of the personal data that we collect about you
- how and why we collect and use your personal data
- how long we keep your personal data for
- when, why and with who we will share your personal data
- the legal basis we have for using your personal data
- the effect of refusing to provide the personal data requested
- the different rights and choices you have when it comes to your personal data
- how we may contact you and how you can contact us.
3. INFORMATION WE MAY COLLECT FROM YOU AND HOW IT IS USED
We may collect and process the following personal data about you:
3.1 “Registration Information” that you choose to provide to us including your:
- areas of social and environmental interest;
- email address; and
- any additional information about yourself.
This Registration Information is available to view on your profile page. If you have entered the information on semble.org, you may change it at any time on your profile page. Please update any changes to this information as soon as possible to help us ensure that the data we hold about you is accurate.
Our legal basis for processing your Registration Information (or other personal data that you provide to us on our Site or communicate to us by telephone, e-mail or otherwise) is to provide you with the Semble Service, including to:
- register you as an account holder (or project administrator);
- send you service emails (as explained in more detail in section 4 below).
If you fail to provide us with such personal data, we may not be able to provide you with the Semble Service.
Our legal basis for processing the personal data included in the information related to your visits to our Sites is that it’s necessary for our legitimate interests to:
- improve our Site and services; and
- administer and protect our organisation and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
We will use your email address to communicate with you as set out below. You can update the email address we use to communicate with you at any time by adjusting your settings on your profile page.
4.1 Service emails to users registered with Semble (“Registered User(s)”)
Once you have set up an account on Semble, we will send you the following types of emails to help you use and benefit from the Semble Service:
- to send you service messages, such as to validate your account, welcome you and provide further information on the Semble Service, or notify you of a service suspension;
- to provide you with the latest news and information on the Semble Service, such as:
- Semble run funding opportunities or volunteer support opportunities to support the delivery of community projects;
- Semble run events and guides for community groups to support them to connect and grow;
- partner run events, funding and other opportunities to help resource an community action;
- free giveaways, such as community action event tickets to support connection with likeminded people;
- surveys to assess the needs of Registered Users, including project administrators in the network; and
- invitations or reminders to get involved in the Semble network, such as to promote your events, share your stories or receive further support
Our legal basis for sending you service emails is to provide you with the service you have requested by signing up for a Semble account.
4.2 Semble newsletters
We will ask your permission to be added to our mailing list to receive our Semble newsletter, with information about Semble campaigns and their impact to encourage the support and delivery of community projects and encourage community action.
Our legal basis for sending you the Semble newsletter is your consent, which can be withdrawn at any time. If you decide you no longer want to receive the Semble newsletter you may opt out at any time by clicking the “Unsubscribe” link at the bottom of the email.
4.3 Emailing other Registered Users through the Semble Service
We do not make your email address directly available to anyone through the Semble Service. Of course, this doesn’t apply if you disclose your email address by posting it on the Site or by sending it to another Registered User.
The only legitimate way of making contact with another Registered User or Project Page found on the Semble Service is for a Registered User to enter a message that we will send on their behalf.
We will notify the addressee, using the email address provided to us that Semble is holding an email for him/her, and the Registered User can collect the email when logged in to the Semble Service. Registered Users may check and (if required) change the email address we hold for them at any time through their “Account Settings” or by emailing us at: firstname.lastname@example.org.
Sent and received emails may appear in a Registered User’s Inbox on the Semble Service for as long as reasonably necessary. We may delete emails without notice for any reason.
5. SHARING YOUR DATA
We may share your personal data in the following ways:
- if all of the assets (or substantially all of them) which Semble uses to operate are acquired by a third party, we may transfer personal data we then hold to that party so that the acquirer can continue to provide the Semble Service; and
- we may from time to time share anonymised data relating to your visits to our Site (including but not limited to traffic data) and the resources that you access to our partner organisations, such as content partners.
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, 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.
7. OTHER SITES
Our Site may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
8. REMOVING YOURSELF FROM THE SEMBLE SERVICE
You may have your Registration Information removed from the Site at any time. To do so please contact us (see section 10) and we will remove all your Registration Information from the public area of the Site within 1 calendar month from the date that your request was received.
Note that if you have asked for your Registration Information to be removed from the Site, it will no longer be visible on the Site but it will be archived and securely stored for as long as reasonably necessary to fulfil the purposes we collected it for and for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Please note that a Registered User’s content may have been copied or stored by other Registered Users and may remain even after it has been removed from the Site. It may also remain cached and archived by those that have copied it.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
9. WHAT ARE YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA
You have the following rights in respect of your personal data:
- The right to rectification – you are entitled to have your data corrected if it is inaccurate or incomplete.
- The right to erasure – this enables you in some circumstances to request and obtain the deletion of your data where there is no legal reason for us to keep using it.
- The right to restrict processing – you have rights to suspend further use of your data, whereby we can still store your data but cannot use it further.
- The right to data portability – you have rights in some circumstances to request the transfer of your data to yourself or to a third party.
- The right to object to processing – you have the right to object to certain types of data processing, including for direct marketing purposes, such as receiving our newsletter.
- The right to withdraw consent – where we are relying on consent to process your data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your data with your consent up to that point is unlawful).
10. DO WE TRANSFER YOUR DATA INTERNATIONALLY
In some instances, Semble will work with overseas partners outside the European Economic Area or the United Kingdom on projects or campaigns, for instance in the global Outdoor Classroom Day campaign, and may share anonymised statistical data. Semble will not share your personal data with any overseas partners without first gaining your express permission.
The privacy laws of the country where the relevant partner is located may be different from those in the UK (where we are based and where your data is stored). If we transfer data to a country that has not been deemed to provide adequate data protection standards, we will ensure that adequate safeguards are in place with the recipient to protect your personal data. You may ask us for a copy of these safeguards by emailing email@example.com.
10. CONTACTING US
Should you wish to make a complaint about our handling of your personal data, you may contact the UK’s Information Commissioner’s Office at https://ico.org.uk/concerns/handling/ or on +44 (0)303 123 1113.