Privacy Policy

INTRODUCTION

This privacy notice applies to all users and prospective users of Nurture Academy Ltd. services (including, but not limited to, parents of and/or persons with parental responsibility for users and prospective users, school client key contacts, corporate client key contacts, course attendees and salon service users), as well as to donor and/or funder key contacts and to prospective donor and/or funder key contacts and attendees and prospective attendees at Nurture Academy fundraising events (“you”, “your”).

This privacy notice covers personal information that is held electronically and also applies to personal information which forms part of a well-structured paper-based filing system.

In this privacy notice a reference to “Nurture Academy”, “we”, “us” or ‘our” is a reference to Nurture Academy Ltd.

THE TYPE OF PERSONAL INFORMATION WE COLLECT

In the course of our dealings and/or ongoing relationship with you we may process the following information relating to you:

Information received from you:

Personal contact details such as name, title, address, telephone numbers, business email addresses and personal email addresses
Age
Gender
Information and opinions expressed during or following participation in any events we run

Special category personal information

Special category personal information relates to information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.

We may process details of any relevant physical health conditions, such as allergies to foodstuffs and/or hair or other products provided as part of our services.

HOW WE OBTAIN YOUR PERSONAL INFORMATION

Some of the personal information we process may be provided to us directly by you.

We may also receive personal information indirectly, from the following sources:

your parent(s) or other person(s) who has/have parental responsibility for you (including foster carers)
your school

Personal information may also be created as a result of our ongoing relationship with you.

HOW WE USE YOUR PERSONAL INFORMATION

We use the information you have given us in the following circumstances:

where we need to perform the contract we have entered into with you;
where we need to comply with a legal obligation; and
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.

We may also use your personal information in the following situations, which are likely to be rare:

where we need to protect your interests or someone else’s interests;
where it is needed in the public interest; and
where you have given your consent.

Situations in which we will use your personal information

We need all the categories of personal information described above primarily to allow us to:

* perform our contract with you;

** enable us to comply with our legal obligations; and

*** pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests

The situations in which we will process your personal information are listed below. We have indicated by asterisks from the above list the principal legal basis upon which we are processing or will process your personal information. Please note, however, that some of the grounds for processing will overlap and there may be several grounds which justify our use of your personal information. Where the legal basis of legitimate interests is applicable, we explain what these are in italics.

To establish and manage our relationship with you and to provide services to you (including with respect to the projects we run in which you participate). *
To carry out business operational and administrative activities (including record-keeping and audits) and to ensure security and business continuity. *
To carry out statistical and other analysis (including behavioural analysis). ***In order to manage our business and to provide the best services to you we need to understand and analyse their use by you.
To comply with the request or requirement of any court of any relevant jurisdiction or any relevant tribunal, mediator, arbitrator, ombudsman, taxation authority or regulatory or government authority. **
As is reasonably necessary to trace you, e.g. to trace debtors and enforce or seek to obtain settlement of amounts owing to us due to default of payment. ***We need to be able to recover monies that you owe to us which may require additional processing of your personal information, for example you have changed your address without telling us.
For use in connection with any legal proceedings (including prospective legal proceedings) and for obtaining legal advice or for establishing, exercising or defending legal rights. ***In order to protect our position in relation to legal proceedings we may need to analyse records including your personal information and share it with our professional advisors, third parties and the courts.

Special category personal information

Data processing may include the processing of special category personal information about you. Such special category personal information requires higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information,

We may process special category personal information in the following circumstances:

In limited circumstances, with your explicit written consent;
Where we need to carry out our legal obligations and in line with our data protection policy; and
Where it is needed in the public interest and in line with our data protection policy.

Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

The most common processing of special category information by us occurs when:

you tell us you or your child, or a child over whom you have parental responsibility, is allergic to a particular foodstuff or hair product/ingredient

DISCLOSURE OF PERSONAL INFORMATION BY US

We may disclose personal information in the situations referred to above:

to Nurture Academy volunteers and/or any third parties who provide services to us or act as our agents (or prospective volunteers, prospective third-party service providers or prospective agents). We will take all reasonable steps to ensure that such volunteers, third party service providers or agents are subject to appropriate data processing requirements;
to third parties in connection with a potential or actual reorganisation (including investment), amalgamation, merger or transfer or sale of all or part of our business, including to any insurers and professional advisors and any third parties to whom we assign, transfer or charge our interest in any product or service provided to you;
to any court of any relevant jurisdiction or any relevant tribunal, mediator, arbitrator, ombudsman or taxation authority or any regulatory authority and any party appointed or requested by them to carry out investigations or audits of our activities;
if we or any person to whom your information is disclosed have a right or duty to disclose it or are permitted (acting reasonably) or compelled by applicable laws and regulations to disclose it;
to debt collection agencies;
to our agents, auditors and professional advisors to enable them to process the information in the situations described above as a data processor on behalf of Nurture Academy and/or as a data controller and to enable them to perform their obligations;
to insurers; or
if you consent to such disclosure.

We will not sell or transfer your personal information to any third party for that party to use for direct marketing purposes without your prior consent

We use cookies and similar technologies to recognise you, remember your preferences and tailor the content we provide to you. In relation to our website, please refer to our Cookie Policy which is available at: www.nurtureacademy.org.uk

RETENTION OF PERSONAL INFORMATION

We will retain personal information for as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, accounting, reporting or internal policy requirements. To determine the appropriate retention period for personal information we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means and the applicable legal requirements. In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Further information on the periods for which we retain your personal information can be requested from the Managing Director, whose details are below.

YOUR DATA PROTECTION RIGHTS

Under data protection law, you have rights including:

Your right of access: You have the right to ask us for copies of your personal information.

Your right to rectification: You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure: You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing: You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing: You have the tight to object to the processing of your personal information in certain circumstances.

Your right to data portability: You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at admin@nurtureacademy.org.uk and/or Nurture Academy, Quebec Wharf, 14 Thomas Road, London E14 7AF if you wish to make a request.

HOW TO COMPLAIN

If you have any concerns about our use of your personal information, you can make a complaint to:

Managing Director

Nurture Academy Ltd

Quebec Wharf

14 Thomas Road

London E14 7AF

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk

CHANGES TO THIS PRIVACY NOTICE

We reserve the right to update this privacy notice at any time and we will notify you either in writing or by updating this privacy notice on our website at: www.nurtureacademy.org.uk/ when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.

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