Shine Together CIC, is a registered Community Interest Company, Registration 14696904 takes your privacy seriously. We are committed to protecting your personal information. This policy sets out how Shine Together CIC uses the information that you provide us with to help further our community aims.
About us: Shine Together CIC is a network for businesswomen. Our different levels of membership all you to access, insights, articles and resources from registered professionals.
Your personal information is not sold, lent or hired with other third parties, but we may sometimes share your information with trusted service providers who are authorised to act on our behalf or whom we work with in partnership. In addition, we may be requested to exchange your personal information with other organisations for the purposes of fraud and credit risk reduction. In these circumstances we always require strict compliance with our instructions and in the case of third party organisations, require that your personal information not be used for their own personal purposes.
Your Information – what we collect and how we use it
Shine Together CIC collects information from you in several different ways. This may include information such as your name, date of birth, ethnicity and contact information. We use this information to help us provide and improve our services as a company and to keep a record of our communications with you.
If you are a paid member of Shine Together CIC we will ask for information that enables us to administer your payment. This will normally include information such as your name, contact details such as address, email or telephone number and your payment details.
If you have given us your consent, we will contact you with information and updates on our products and services. This may be by post, email, telephone or text message, depending on your preferences. We will also continue to ask about your marketing preferences, to ensure that you are still happy to be contacted by us and by which means.
What the Law says about protection of personal information
The Law on Data Protection is derived from various pieces of legislation (can be found in a number of places). These include the Data Protection Act and the incoming General Data Protection Regulation (the ‘GDPR’) which became enforceable in May 2018. The GDPR states that personal data (information relating to a person that can be individually identified) can only be processed if there is a legal ground to do so. Activities like collecting, storing and using personal information would fall into the GDPR’s definition of processing. The GDPR provides six legal grounds (reasons) under which personal information can be processed (used) in a way that is lawful. For the processing to be permitted by law (lawful), at least one of the legal grounds must apply.
The four legal grounds that are most relevant to Shine Together CIC, usage of your personal information are:
- Legitimate Interest
- Legal Obligation
How the law applies to Shine Together CIC use of personal information, we will only process (use) your personal information if we have:
- asked you and have a record of your express and recent consent for us to do so;
- a ‘Legitimate Interest’ to do so in order to support our company purposes. Our use will be fair and balanced and never unduly have an impact on your rights;
- a contract with you that we can only fulfil by using your personal information, e.g. access to mentors and resources based on your membership;
- a legal obligation to use or disclose information about you, e.g. we are required by law to keep records of our members for 6 years
We will not unduly prioritise our interests as a company over your interests as an individual. We will always balance our interests with your rights. We will only use personal information in a way and for a purpose that you would reasonably expect in accordance with this Policy.
Shine Together will not rent, swap or sell your personal information to other organisations for them to use in their own marketing activities.
Shine Together CIC will always ask for your consent before we communicate with you for certain purposes. For example, we will only email or phone you if we have an accurate record of your recent and freely given consent to do so.
You can withdraw your consent at any time by unsubscribing from our emails or by Contacting us at Admin@shine-together.com.
There are times when it is not practical to obtain and record consent. At those times, we will only process personal information if that processing would meet another legal ground e.g. Legitimate Interests, in which case we would only process in accordance with the law’s strict rules on legitimate interest processing.
What is Legitimate Interest
This legal ground for processing means that organisations can process your personal information if they:
1) have a genuine and legitimate reason for doing so, and
2) that use does not harm any of your rights and interests as an individual.
We do not unduly prioritise our legitimate business interests as a company over your interests as an individual. We always respect your rights, which is why we carry out a balancing exercise of the rights of the company with the rights of our members.
The four groups for our data protection members needs are members that have:
- subscribed to the platform
- attended company events or taken part in company events
- provided financial details for membership
- demonstrated an interest in our company by contacting us for more information, e.g. to find out more about one of our events or programmes.
What we have a Legitimate Interest to do
We believe that Shine Together CIC members are connected to our mission and want to know how they can continue to help us to achieve our company vision. Unless you tell us not to, we think you give consent for us to process (keep and use) your personal information for the time the business is operational.
These are members that have paid to access features within the platform. These members will hold the same principles and values and do continue to support the company.
Demonstrated an interest in Shine Together CIC via an enquiry
These are individuals who have demonstrated an interest in our company by contacting us for more information, e.g. to find out more about one of our events. We think someone that has reached out to us to find out more about our work and what we do, would like us to provide that information; perhaps a little more information; and even some support in fulfilling their initial query or request. To support this, we keep your personal information for a period of 2 years.
Legitimate Interest to send you direct mail
Unless you tell us not to, we will rely on our Legitimate Interest ground (explained above) for sending you direct mail. From time to time, we would like to post you updates about our work, and how you can support us, including events and resources. Unless you have requested that we do not send you some, or all of this, our direct mailings do include marketing.
We are always mindful of trying to only send you what you are interested in and only as often as is appropriate. If we do not appear to be sending communications that are of interest, we will review this and will endeavour to reduce and then stop these types of communications in a much shorter time than the above defined period of Legitimate Interest e.g. if you came to an event three years ago and do not seem to have been interested since then we are likely to reduce these communications, even though we have a legitimate interest to process for 6 years. The average length of time required for us to be able to properly assess and reflect on your pattern of response is about two years. But you’re in control so if you want to ensure that we do not send this type of communication anymore, you can update your preferences at any time or opt out by Contacting email@example.com
Legitimate Interest to process your information
We aim to be clear about what information we collect, to enable you to make meaningful choices about how it is used.
When it is necessary, we will contact you for administrative purposes, e.g. to contact you regarding a payment. We will also hold the minimum personal information required to support our ability to respect your preferences for communication with us.
To help you to understand when and why Shine Together CIC would use Legitimate Interest to process your personal information we provide the following examples:
- To send postal communications
- To enhance, modify, personalise and improve our communications for the benefit of our members.
- To improve security of our websites and systems.
- To prevent fraud when transacting on our website.
- To process your membership.
- To take payment.
- To analyse your personal information to ensure that our communications are relevant to you.
The above list of examples are on the basis that the processing will not be done if it harms your rights and interests as an individual, or if you tell us that you’d like us to stop. You can do this at any time by opting out or emailing firstname.lastname@example.org.
In order to communicate with you more effectively, better understand your preferences and ability to support our work, we may analyse your data.
We like to find out about your personal motivation for supporting us and your experiences as a member. In some instances, we may carry out research and/or analysis of the personal information that you have provided to us and add publicly available information (such as public records or social media) to help us tailor our communications to you, this may include ethnicity screening. We do this to create a fuller picture of our supporters/members, to improve our service. This information could include things like your interests, location, ethnicity and the level of any potential donations.
To help us communicate the work we are doing and provide these services we use trusted service providers, marketing agencies and direct mailing providers.
Shine Together CIC does not share, sell or swap your information with other organisations for their own marketing outside of our group.
In some circumstances it is necessary for Shine Together CIC to give relevant staff at our service providers access to your personal information. This access is only granted to the extent necessary for them to perform their services for us. We require all service providers to comply with strict rules to protect the information you have given us.
Changes to your data
From time to time we may contact you to ensure that the information you have provided us with remains accurate and up to date.
Should you wish to change your preferences, amend or correct the details we hold you can do this in your online profile, or by email addressed to email@example.com.
Like all organisations, we comply with requests for the disclosure of personal information where this is required or permitted by law. This could include requests from law enforcement or tax agencies. In these circumstances, the request must be submitted in writing and in accordance with the relevant legal requirements.
If you believe your privacy rights have been violated, you may file a complaint with us or with the Information Commissioners office https://ico.org.uk/
Cookies and Web Privacy
Shine Together CIC guarantee our commitment to respecting and protecting your online privacy.
This includes your need and your right to know what we do with the personal information you share with us. It also guides our company’s policies regarding the management of this data, including how the information is collected, processed, and for what purposes.
How do we collect information?
For each visitor to our website, we collect and store information regarding how you use the site, the pages you visit and time spent on each page.
What information do we collect?
Personal information we collect is any information that can be used to identify you. This can include information such as name, postal address, email address and phone number.
In addition to this, we also collect general information about the use of our websites, such as which pages users visit and which services, events or information are of most interest. We also may track which pages users visit when they receive and click on links in Shine Together CIC emails. Wherever possible, we use aggregated or anonymous information, which does not identify individual users to our websites.
How do we use this information?
We will use your personal information to enable us to give you the information, support, services or products you require, with the purpose of contacting you with the information you have requested. Any payment card information supplied when you subscribe as a member will be hosted in a secure area protected by encryption through SSL certificates and will only be used in the explicit way that the user agrees to (one off fee, or in the set up of a regular payment).
Where relevant we may ask for your consent to use this information to contact you from time to time with information that may be of interest to you. If you indicate that you do not want to be contacted for marketing purposes as mentioned above, we will not use your personal information in that way.
Your personal information is not sold, lent or hired with other third parties, but we may sometimes share your information with trusted service providers who are authorised to act on our behalf or whom we work with in partnership. In addition, we may be requested to exchange your personal information with other organisations for the purposes of fraud and credit risk reduction. In these circumstances we always require strict compliance with our instructions and in the case of third party organisations, require that your personal information be not used for their own personal purposes.
Links From Our Website
The Shine Together CIC website does contain external links to other websites and this statement applies to pages on the Shine Together CIC site only (these are pages hosted on the www.shine-together.com). Please be aware that other websites may have other privacy policies in place and we are not responsible for the privacy practices of external websites.