PURPOSE OF THIS PRIVACY NOTICE
Advantages of Age Limited, (“Advantages of Age”, “we”, “us” or “our”) are committed to protecting and respecting your privacy.
Advantages of Age respects your privacy and is committed to protecting your personal data. This privacy notice informs you as to how we look after your personal data when you visit our website (regardless of where you visit it from), other channels or otherwise correspond or interact with us. This privacy notice also tells you about your privacy rights and how the law protects you. Please read this notice carefully to understand our practices regarding your personal data and how we will treat it.
YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
CONTROLLER AND CONTACT DETAILS
Advantages of Age is a controller under applicable data protection laws, such as the Data Protection Act 2018, EU General Data Protection Regulation and UK General Data Protection Regulation, and is therefore responsible for the personal data we process about you. If you have any questions about this privacy notice, including any requests to exercise your legal rights in respect of your personal data, please contact us using the details set out below.
Full name of legal entity: Advantages of Age Limited
Email address: email@example.com
Postal address: 11a Priory Road, London NW6 4NN, United Kingdom
This website may include links to third-party websites. We do not control these third-party websites and are not responsible for their privacy practices. When you leave our website, we encourage you to read the privacy notice of every website you visit.
INFORMATION WE COLLECT ABOUT YOU
“Personal data” means any information about an identified or identifiable living individuals. It does not include data where the identity has been removed (anonymous data). We may collect and process different kinds of personal data about you, which we have grouped together as follows:
- Identity Data includes [name, username or similar identifier, marital status, title, date of birth and gender].
- Contact Data includes [address, billing address, delivery address, email address and telephone numbers].
- Education and Employment Data includes [qualifications attained, status of employment or rationale for unemployment].
- Financial Data includes [financial earnings (including receipt of any state benefits), bank account and payment card details].
- Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us].
- Technical Data includes [internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website].
- Profile Data includes [your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses].
- Usage Data includes [information about how you use our website, products and services].
- Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
- [Describe any other types of personal data which are collected and/or used].
We may also collect, store and use the following types of personal information that are categorised as “sensitive” or “special category data”, which we have grouped together as follows:
- Background Data includes [information about your race or ethnicity, immigration status or citizenship status, religious beliefs and sexual orientation].
- Health Data includes [information about your health, including any medical conditions and disability information].
We do not collect any other special categories of personal data about you, nor do we collect any information about criminal convictions and offences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your [Identity Data, Contact Data, Financial Data, Education and Employment Data, Background Data and Health Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- [respond to any questionnaires;]
- [purchase our products or services;]
- [create an account on our website;]
- [subscribe to our publications;]
- [request marketing to be sent to you;]
- [give us feedback or contact us.]
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
- [Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
- analytics providers [such as Google based outside the UK];
- advertising networks [such as [NAME] based [inside OR outside] the UK]; and
- search information providers [such as [NAME] based [inside OR outside] the UK].
- Contact and Transaction Data from providers of technical, payment and delivery services [such as [NAME] based [inside OR outside] the UK].
- Identity and Contact Data from data brokers or aggregators [such as [NAME] based [inside OR outside] the UK].
- Identity and Contact Data from publicly available sources [such as Companies House and the Electoral Register based inside the UK].
- [ANY OTHER WAYS YOU COLLECT PERSONAL DATA].]
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when and how the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although, where required by law, we will get your consent before sending direct marketing communications to you via email or text message. In such circumstances, you have the right to withdraw consent to marketing at any time by contacting us.
For further details on the purposes for which we use your personal data and the legal bases (including legitimate interests) that apply in such circumstances, please see “PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA” below.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a new member/user and provide services to you (such as enrolling you in a programme)||Identity DataContact DataEducation and Employment DataFinancial DataTransaction DataMarketing and Communications DataBackground DataHealth Data||Performance of a contract with youNecessary for our legitimate interests (to obtain funding from local councils)Your consent (where required and obtained from you in relation to Background Data and Health Data, in order to obtain funding from local councils)|
|To manage our relationship with you which will include:Notifying you about changes to our terms or privacy noticeAsking you to leave a review or take a survey||Identity DataContact DataProfile DataMarketing and Communications Data||Performance of a contract with youNecessary to comply with a legal obligationNecessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)|
|To enable you to publish content on the website or partake in a prize draw, competition or complete a survey||Identity DataContact DataProfile DataUsage DataMarketing and Communications DataBackground DataHealth Data||Performance of a contract with youNecessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)Your consent (where required)Data manifestly made public (in relation to Background Data and Health Data)|
|To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity DataContact DataTechnical Data||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)Necessary to comply with a legal obligation|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Identity DataContact DataProfile DataUsage DataMarketing and Communications DataTechnical Data||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)Your consent (where required)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Technical DataUsage Data||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)Your consent (where required)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||Identity DataContact DataTechnical DataUsage DataProfile DataMarketing and Communications Data||Your consent (where required by law and obtained)Necessary for our legitimate interests (to develop our products/services and grow our business)|
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Education and Employment Data, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications by email or text from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. In other circumstances, we will get your express opt-in consent before sending such marketing to you.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.]
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, product experience or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
WHO MIGHT ADVANTAGES OF AGE SHARE MY PERSONAL INFORMATION WITH?
Advantages of Age may transfer personal data to third parties for the purposes set out above as follows:
- Communication with third parties. As necessary in connection with Advantages of Age’s operations, Identity Data, Contact Data, Education and Employment Data, as well as certain Financial Data, Background Data and Health Data (solely to confirm that you meet the requirements set by local councils to provide us with funding) may be transferred to existing or potential partners, suppliers, clients, intermediaries, professional advisors, government officials and other third parties.
- Regulators, authorities, and other third parties. Where necessary, personal data may be transferred to courts, and other authorities (e.g., tax and law enforcement authorities), independent external advisors (e.g., auditors), insurance providers, payroll agents, pensions and benefits providers, internal compliance and investigation teams (including external advisers appointed to conduct internal investigations).
- Data processors. Personal data may be shared with one or more third parties, whether affiliated or unaffiliated, to process personal data under appropriate instructions (“Data Processors”). The Data Processors may carry out instructions related to administration, IT system support and maintenance, compliance and other activities or services, and will be subject to contractual obligations to implement appropriate technical and organisational security measures to safeguard the personal information, and to process the personal information only as instructed by us.
- New owners. Personal data may be shared with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
[PLEASE INCLUDE ANY OTHER EXAMPLES]
We may transfer personal data outside of the UK and/or European Economic Area, including to countries in respect of which the UK Government or European Commission has not issued an adequacy decision. This means that such countries are not deemed to provide an adequate level of protection for your personal data. If such transfers take place, they will be in accordance with Data Protection Laws, including through the use of standard contractual clauses that have been approved by the UK Government, European Commission or other relevant authorities, or where we are entitled to rely on one of the other safeguards permitted by applicable law (such as obtaining your consent to transfer personal data, where the transfer is necessary for the performance of a contract between us or where a contract was entered into on your behalf, or where the transfer is necessary to establish, exercise or defend legal claims).
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
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, agents, 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.
HOW LONG WILL YOU RETAIN MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting 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.
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.
In some circumstances you can ask us to delete your data: see YOUR LEGAL RIGHTS below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
The Data Protection Laws give you certain rights in respect of the personal information that we hold about you. Details of these rights are set out below:
- Access. You have the right to confirm with us whether your personal data is processed, and if it is, to request access to that personal data including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. We do have to take into account the interests of others though, so this is not an absolute right, and if you want to request more than one copy we may charge a fee.
- Rectification. You may have the right to rectify inaccurate or incomplete personal data concerning you.
- Erasure. In limited circumstances, you may have the right to ask us to erase personal data concerning you.
- Restriction. You also have the right to ask us to restrict the processing of your personal data in certain circumstances, for example, if you believe that your personal data held by us are inaccurate, if processing of your personal data is unlawful, or if we no longer need your personal data for the purposes for which they were collected, but you require your personal data to establish, exercise or defend legal claims.
- Data Portability. You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another entity.
- Right to Object. Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us and we can be required to no longer process your personal data. This may include requesting human intervention in relation to an automated decision so that you can express your view and to contest the decision.
- Marketing. You have the right at any time to ask us not to process your personal data for direct marketing purposes, including profiling if it is related to such direct marketing. If you object to the processing for direct marketing purposes we will no longer process your personal data for such purposes.
You also have the right to lodge a complaint with the competent data protection supervisory authority, which in the UK is the Information Commissioner’s Office (contact details are available at: https://ico.org.uk/global/contact-us/). We would, however, appreciate the opportunity to deal with your concerns before you approach a supervisory authority, and so ask you to please contact us in the first instance.
If you wish to exercise any of the rights set out above, please contact us using the details above.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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