Privacy Policy

Data Protection Policy/Privacy Policy

Elevate Guildford Limited Trading as Experience Guildford

Privacy Policy – Updated 01 May 2018

Elevate Guildford has always taken great care over the data that we hold for the clients and contacts that we work with.

Our updated Data Protection Policy is detailed below and will also be available on our website in May 2018.

Our Privacy Policy – your information, your rights and how we use it

Elevate Guildford Limited is committed to protecting your personal information. Our Privacy Policy was last updated on 01 May 2018.

Our Privacy Policy contains important information about what personal details we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.

We may need to make changes to our Privacy Policy. More detail can be found on our website, which may be updated over time. If there are important changes such as changes to where your personal data will be processed, we will contact you to let you know.

If you require access to the data we hold on you, we may require additional information from you to confirm your identification before we release any data we hold.

Who we are

We are Elevate Guildford Limited (“Elevate Guildford Limited”), trading as Experience Guildford.

This Privacy Policy applies to Elevate Guildford Limited, Guildford, Surrey.

How to contact us

If you have any questions about our Privacy Policy or the information we collect or use about you, please contact:

FAO Data Controller Elevate Guildford Limited Stevenson House, 16a Tunsgate, Guildford, Surrey. GU1 3QT Email: [email protected]

Information we collect and use

Information about you that we may collect and use includes:

  • Information about who you are e.g. your name, date of birth, address and contact details
  • Information about your contact with us e.g. meetings, emails/letters and phone calls
  • Information that is automatically collected e.g. via cookies when you visit our website

What are cookies?

A cookie is a small file – it is saved onto your computer or other device when you visit our website.

Cookies store small pieces of information. For example – they will remember that you have visited our website or performed a certain action.

We use cookies to help us improve your experience when you visit our website. For example, a cookie might store information so you don’t have to keep entering it.

Cookies also let us know which pages of our website you visited; they help us develop and market our products and services.

Persistent cookies – these stay valid, and will work until their expiry date (unless you delete them before they expire)

Session cookies – these expire when you close your web browser

Our website contains links to other websites, including social media sites and apps. We are not responsible for the content or privacy practices (including the delivery of any cookies) of these websites. We strongly encourage you to read the privacy policies of those websites before providing those third parties with your information.

Where we collect your information

We may collect your personal information directly from you, from a variety of sources, including:

  • An application form for a product or service
  • Phone conversations with us
  • Emails or letters you send to us
  • Meetings with one of our team members
  • Registering for an event with us e.g. Customer Service Awards
  • Participating in research surveys to help us understand you better and improve our products and services
  • Our online services such as websites, social media and mobile device application (‘Apps’)

What we collect and use your information for

We take your privacy seriously and we will only ever collect and use information which is personal to you where it is necessary, fair and lawful to do so. We will collect and use your information only where:

  • It is necessary to provide the product or service you have requested e.g. Privilege Card
  • It is necessary for us to meet our contractual, legal or regulatory obligations e.g. accounting for promotional prizes and to tell you about changes to Terms and Conditions or for the detection and prevention of fraud
  • It is in the legitimate interests of Elevate Guildford Limited e.g. to deliver appropriate information and guidance so you are aware of the options that will help you get the best outcome from our services
  • Where we need to process your information to better understand you and your needs so we can send you more relevant communications about the products you have with us and to develop new products and services
  • It is in the legitimate interests of a third party e.g. crime reduction
  • It is necessary for us to meet our legal or regulatory obligations e.g. to verify your identity
  • It is in the legitimate interests of Elevate Guildford Limited e.g. to understand our user demographics and use of our website and online products
  • To send invoices or reminder notices or otherwise notify you of changes to our online products or services, and any other purpose related to or ancillary to any of the above.
  • You have given us your permission [consent] to send you information about products and services offered by other parts of Elevate Guildford Limited.

If you do not wish us to collect and use your personal information in these ways, it may mean that we will be unable to provide you with our products or services.

Who we may share your information with

We may share your information with third parties for the reasons outlined in ‘What we collect and use your information for.’

These third parties include:

  • Elevate Guildford Limited employees
  • Companies we have chosen to support us in the delivery of the products and services we offer to you or companies who can help us in our contact with you, for example, an internet service provider.

Where we wish to share your personal information with third parties who are not listed above then we shall seek your consent before doing so, unless the data is anonymised (i.e. it does not identify individuals) – in which case we may share the information without first obtaining your consent.

We will never sell your details to someone else. Whenever we share your personal information, we will do so in line with our obligations to keep your information safe and secure.

Where your information is processed by Elevate Guildford Limited

All of the information provided to Elevate Guildford Limited is processed by us in the UK.

How we protect your information

We take information and system security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected, recorded or used in any way, whether on paper, online or any other media, will have appropriate safeguards applied in line with our data protection obligations.

Your information is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. Our employees also protect sensitive or confidential information when storing or transmitting information electronically and must undertake training on this.

Our security controls are aligned to good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of your information.

Protection of Personal Data

Protection of all client information provided or received by us is of paramount importance to our company. Elevate Guildford goes to great lengths to ensure that the information provided to us in the course of our business is kept secure at all times. Elevate Guildford is a Data Controller under the GDPR, in line with the Data Protection Act 2018 (the ‘Act’) and any personal and financial information that we hold about you will be held on secure server/computer and/or in paper files and processed subject to the GDPR. This information will be used to deal with queries and to bring to your attention additional services and products that may be of benefit to you. If we are advised that the confidentiality of your information is breached, we will inform you as soon as possible if the breach is likely to result in a high risk of adversely affecting your rights and freedoms. We also have a duty to report certain types of personal data breach to the relevant supervisory authority within 72 hours of becoming aware of the breach, where feasible. We will document all breaches regardless of whether or not reporting is required.

How long do we keep your information?

We have detailed in this Privacy Policy the ways in which individuals can have their information erased from our records or request amendments to the data we hold.

The information we hold for individuals will be maintained for the course of our Business Improvement District term, which is renewed by business ballot every five years. We will hold your information to provide you with our products or services while you are a customer. On renewal of our mandate (next due January 2023), we will continue to hold your information, noting your standard rights below. If our mandate is not renewed we will delete your information on the closure of the business.

This is because the Experience Guildford Privilege card, as an example, is an open-ended service. You have control as to the way you use the Privilege card within the parameters of the scheme. This allows us to create generic marketing information for our retailers to provide further benefits to our cardholders into the future.

We will maintain Business Levy payer information for the course of the BID term(s) for management and accounting reference.

The individual rights available to you

You have several rights in relation to how Elevate Guildford Limited uses your information. They are:

Your right of access

You have the right of access to your personal information. If you wish to receive a copy of the personal information we hold on you, you may make a data subject access request.

We reserve the right to charge a small administration fee for requests that are manifestly unfounded or excessive.

Your right to be informed

You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with, if at all.

Your right to request erasure

We shall, upon receipt of a written request from the Customer, return all Customer Personal Data at the end of the provision of the Services to which the Customer Personal Data relates. This will not apply to any Customer Personal Data that we must retain in accordance with any legal and regulatory requirements, and will be directed by any guidance that has been issued in relation to deletion or retention by a Supervisory Authority.

You can ask for your information to be deleted or removed if there is not a compelling reason for Elevate Guildford Limited to continue to have it.

We reserve the right to charge a small administration fee for requests that are manifestly unfounded or excessive.

Your right to request that your personal information be rectified

If your personal information is inaccurate or incomplete, you can request that it is corrected.

We reserve the right to charge a small administration fee for requests that are manifestly unfounded or excessive.

Your right to restrict processing

You can ask that we block or suppress the processing of your personal information for certain reasons. This means that we are still permitted to keep your information – but only to ensure we don’t use it in the future for those reasons you have restricted.

How to make a complaint

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in our Privacy Policy, please contact us directly and we will work to resolve any issues.

If you are still unhappy, you can complain to our Supervisory Authority. Their contact details are:

Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF

Tel: 0303 123 1113 (local rate) or 01625 545 745 if you prefer to use a national rate number Fax: 01625 524 510