Privacy Policy | SEO London

TERMS AND CONDITIONS AND PRIVACY POLICY

Summary

We will not rent or sell our users’ details to any other organisation or individual.

Sponsors for Educational Opportunity London’s (“SEO London”) mission is to help talented and ambitious individuals from underrepresented backgrounds to realise their full potential. As these Terms & Conditions explain, any information you provide to us will be used to help us fulfil this mission.

As part of this mission, we collect sensitive information to determine your eligibility for our programmes. We will take all reasonable care to safeguard this information.

Introduction

SEO London provides access to the SEO London services including its website, available via the URL https://www.seo-london.org/ (the “Website”), and to information, and other materials available on and through the Website. Your use of the Website is subject to our Terms & Conditions, which you are deemed to accept by using the Website.

The Website is owned by SEO London, a private not for profit Charity in England and Wales with company number 4159512 and registered Charity 1097832. SEO London’s registered office address is 41 Great Guildford Street, London, SE1 0ES.

The copyright and all other rights on the material on the Website are owned by SEO London. You may copy material on this site for your own private or domestic purposes, but no copying for any commercial or business use is permitted.

Information on the Website

Whilst we try to ensure that the standard of the Website remains high and the information accurate, errors, omissions, interruptions of service and delays may occur at any time. We do not accept any liability arising from any such errors, omissions, interruptions or delays. Neither do we accept any ongoing obligation or responsibility to operate the Website (or any part of it) or to provide the service offered on the Website. We may vary the specification of this site from time to time without notice.

Use of the Website

You may only use the Website for lawful purposes when seeking or submitting information and applying for opportunities. You must not under any circumstances seek to undermine the security of the Website or any information submitted to or available through it.

You are solely responsible for any information submitted by you to this site. You are responsible for ensuring that all information supplied by you is true, accurate, up-to-date and not misleading. You are also responsible for ensuring that all information, data and files are free of viruses or other routines or engines that may damage or interfere with any system or data prior to being submitted to this site. We reserve the right to remove any information supplied by you from the Website at our sole discretion, at any time and for any reason without being required to give any explanation.

Our Privacy Policy sets out how we collect, use and protect an individual’s “Personal information”. Personal information is information that identifies a living individual or is capable of doing so.

We take your privacy seriously. We are committed to maintaining the privacy and security of your information and providing you with choices regarding our collection and use of your information. This Privacy Policy applies to information we collect about you through the Website and when you otherwise communicate with us.

For the purposes of the European Data Protection Legislation and this Privacy Policy, the data controller is SEO London.

We process your personal data on the basis that you have provided your consent for us to do so for the purposes set out below when you submitted your personal data to us. You may withdraw your consent to this processing at any time by contacting us at data@seo-london.org or Sponsors for Educational Opportunity London, 41 Great Guildford Street, London, SE1 0ES. If you do withdraw your consent, we may still be able to process some of the data that you have provided to us on other grounds. You also have the right, however, to make a complaint to the relevant Supervisory Authority about our use of your information (in most cases under this Privacy Policy the relevant Supervisory Authority will be the Information Commissioner’s Office). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

If you hear from us, we will always aim to be respectful, relevant and appropriate. If at any time you feel we have not lived up to this aim, please let us know straight away by getting in touch with us.

Information we may collect

We may collect and process the following data:

Information you give to SEO London: You may give us information about yourself via the Website, for example by submitting application forms, contacting us via the “Contact Us” page, signing up for the newsletter, online surveys, etc. The information you give to us may include:

identity data, which includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
contact data, which includes billing address, delivery address, email address and telephone numbers;

Information SEO London may collect about you: Each time you visit our Website, we may automatically collect the following information:

technical data, which includes web usage information (e.g. IP address), your login information, browser type and version, time zone setting, operating system and platform; and
access data, which includes information about your visit, including the full Uniform Resource Locators (URLs) clickstream to, through and from seo-london.org (including date and time), time on page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs).
profile data, which includes your username and password, your interests, preferences, feedback and survey responses;
communications data, which includes your preferences in receiving communications from us;
financial data, which includes bank account and payment card details; and
“sensitive data”, which includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, information about your health and genetic and biometric data.

Information we receive from other sources: When we act in connection with certain third parties, we may collect the following information:

SEO London may also receive information about you from our partners or others that we use to make our own information better or more useful. This might be information including how well an online marketing or email campaign performed;
where applicable, we may also on occasion receive information about you from sponsor firms related to your performance or progress in sponsored educational, engagement or recruitment activities.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does 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.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract or other agreement we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will endeavour to notify you if this is the case at the time.

How your personal data is collected

We use different methods to collect data from and about you including through:

Direct interactions: You may give us your data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

create an account on our website;
subscribe to our service or publications;
request marketing to be sent to you; or
give us some feedback.

Automated technologies or interactions: As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy set out below for further details.

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources, including any of our sponsor firms, your universities, or more general publicly available sources on the web.

Cookie policy

Our Website uses cookies to distinguish you from other users, to improve your experience on our Website, and to recommend content that may be of interest to you. When you visit the Website we will ask you whether you agree to our use of cookies. You can indicate your acceptance of our use of cookies by clicking “OK” in the appropriate place on the banner that appears on the Website. However, please note that if you do not click “OK” but continue to browse the Website, you will be deemed to have accepted our use of cookies in accordance with this Privacy Policy. If you do not agree to our use of cookies, then you may continue to use the Website, but your browsing experience may be affected. You can find out more below about what cookies are, the cookies we use and how to switch off cookies.

What are cookies? A cookie is a text file containing small amounts of information, which is downloaded to your device when you access a website. The text file is then sent back to our server each time your browser requests a page from the server. This enables us to operate the Website more effectively and load the Website in such a way as to reflect your personal preferences based on your previous browsing on the Website, as well as keywords we may be able to gather from URLs of webpages from which you accessed the Website.

What cookies do we use? We use the following cookies:

Analytical and performance cookies: We may use analytics service providers for website traffic, analysis, and reporting. Analytics service providers generate statistical and other information about the use of the Website by using cookies. They allow us to recognise and measure the number of visitors, how often visitors return to the Website, how long they stay, and how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily. The information generated relating to the Website may be used to create reports about the use of the Website and the analytics service provider will also store this information.
Advertising and targeting cookies: These cookies record your visit to our Website, the pages you have visited and the links you have followed to other websites. We will use this information to try and make our Website and other websites that you visit more relevant to your interests. We may also share this information with carefully selected third parties for this purpose.
Functionality cookies: We may use functional cookies that allow us to remember choices you have made in relation to the Website to provide a more personalised experience and enhanced user experience by delivering content specific to your interests.
Third party cookies: We try and make it easy to share content and to see what content is popular on those networks. We add buttons to allow people to easily share to those networks. When we include these social ‘plugins’, it gives those sites the flexibility to use cookies. They can’t read any cookies we set from our Website, and we can’t read any cookies they set, but it lets them do the same kind of traffic measuring that we do on the rest of the Website, and it also lets them know whether you’re logged in. Other websites and services (including, for example, advertising networks, providers of external services like web traffic analysis services and content recommendation engines) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

How do I turn cookies off? If you would like to opt out of cookies, you can change the settings on your internet browser to reject cookies. For more information please consult the “Help” section of your browser or visit www.aboutcookies.org or www.allaboutcookies.org. Please note that if you do set your browser to reject cookies, you may not be able to use all the features of our Website.

How we will use your information

We will only use your personal data when the law permits. Most commonly, we will use your personal data in the following circumstances:

where we need to perform any contractually defined activities between us reliant at least in part upon that data;
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; and
where we need to comply with a legal or regulatory obligation.

More specifically, we may use your information for the following purposes:

to respond to any query that you may submit to us;
to determine your eligibility for certain of our programmes in which you have expressed interest in participating;
to measure or understand the effectiveness of our programming delivery, outreach and effectiveness;
to permit us to support you in your career so long as you desire such support;
to ensure that our Website’s content is presented in the most effective manner for you and your computer;
to customise the Website according to your interests;
to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey responses;
to allow you to participate in interactive features of our service when you choose to do so;
as part of our efforts to keep the Website safe and secure;
to comply with the law;
as we feel is necessary to prevent illegal activity or to protect our interests.

Disclosure of your information

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

When we share your information with third parties they will process your information as either a data controller or as our data processor and this will depend on the purposes of our sharing your personal data. We will only share your personal data in compliance with the applicable data protection legislation.

We may disclose your information to third-parties:

when you specifically request this, such as when you submit information to enquire about jobs or submit an application through the Website;
including partner/sponsor organisations that may interest you;
in the event that we sell or buy any business or assets or engage in some form of legal entity combination or consolidation, in which case we may disclose your personal data to the prospective seller, buyer or subsequent owners or trustees of such business or assets;
if the Website or substantially all of its assets are acquired by a third party, in which case personal data held by it about its service users will be one of the transferred assets; or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property or safety of the Website, our service users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

The third parties include:

business partners, corporate donors and sponsors, clients, suppliers and sub-contractors for the performance of any contract we enter or work undertaken with them or you; and analytics and search engine providers that assist us in the improvement and optimisation of the Website.

We may share some broader statistics and customer profiling information with third parties and other partner/sponsor organisations on an anonymous basis, so you would not be identifiable from that data. We will not rent or sell our user’s details to any other organisation or individual.

Usage of imagery and videos

You consent to SEO London using any images, video or content in any format, including digital and print taken of you during my participation on any SEO London event, for the purpose of promoting the work SEO London do in helping underrepresented communities.

Storage of your personal data

If you have any questions about how your data is stored, please contact us directly with your questions at data@seo-london.org.

The data that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or one of our suppliers. By using the Website, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

In this regard, whenever we transfer your personal data out of the EEA, we will aim to ensure a similar degree of protection is afforded to it by implementing certain safeguards. For instance, we will endeavour to only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe, and, where we use providers based in the US, we may only transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

We follow strict security procedures as to how your personal information is stored and used, and who sees it, to help stop any unauthorised person getting hold of it. All personal information you register on this Website will be located behind a firewall. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Unfortunately, the transmission of information via the internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of your data. So we cannot accept any liability for the loss, theft or misuse of the personal information which you have registered on the Website if there is a security breach.

We will keep your information stored on our systems for as long as it takes to provide the services to you. The third parties we engage to provide services on our behalf will keep your data stored on their systems for as long as is necessary to provide the services to you. We will not store your information for longer than is reasonably necessary or required by law.

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 requirements.

Your rights

Even if you have accepted the processing of your personal data for marketing purposes (by ticking the relevant box), you have the right, under certain circumstances, to:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

You can exercise this right at any time by contacting us at data@seo-london.org.

The Website may, from time to time, contain links to and from the websites of sponsors, business partners, advertisers and affiliates, among others. 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.

From 25 May 2018, you will be entitled to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format, and to transmit that data to another data controller. The types of data that can be provided are those set out in the section titled ‘Information we may collect’ above. You can exercise this right from 25 May 2018 by contacting us at data@seo-london.org.

Access to information

European Data Protection Legislation gives you the right to access information held about you. You are entitled to be told by us whether we or someone else on our behalf is processing your personal information; what personal information we hold; details of the purposes for the processing of your personal information; and details of any third party with whom your personal information has been shared. 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 may refuse to comply with your request in these circumstances. Sometimes you may be asked to provide proof of identity before we show you your personal information. This is to prevent unauthorised access. Your rights to access, rectify such information, object or cancel the information we hold about you can be exercised at any time by contacting us at data@seo-london.org.

Contact

Questions, comments and requests should be addressed to:

Address: Sponsors for Educational Opportunity London, 41 Great Guildford Street, London, SE1 0ES
Email address: data@seo-london.org (related to our privacy policy)
Email address: info@seo-london.org (related to everything else)

Definitions

For the purposes of this Privacy Policy, “European Data Protection Legislation” is defined as, for the periods in which they are in force, the European Data Protection Directive 95/46/EC, all laws giving effect or purporting to give effect to the European Data Protection Directive 95/46/EC (such as the Data Protection Act 1998) or otherwise relating to data protection (to the extent the same apply) and, from 25 May 2018, the General Data Protection Regulation (Regulation (EU) 2016/670) (GDPR) or any equivalent legislation amending or replacing the GDPR.