Privacy policy

Who We Are

The Brownlee Foundation (‘we’ or ‘us’ or ‘our’) gather and process your personalinformation in accordance with this privacy notice and in compliance with therelevant data protection Regulation and laws. This notice provides you with thenecessary information regarding your rights and our obligations, and explainshow, why and when we process your personal data.

The Brownlee Foundation’s registered address is 1 London Road, Ipswich, IP1 2HA. We are aregistered charity under charity number 1166638 and we are a company registeredin England and Wales under company number 09362584. We are registered on the Information Commissioner's OfficeRegister; registration number ZA439662, and act as the data controller when processing your data. Our designated Data ProtectionOfficer/Appointed Person is Chris Smith, who can be contacted at 1 London Road,Ipswich, IP1 2HA. Email: Chris@gmsfc.co.uk

Information That We Collect

The Brownlee Foundation processes your personalinformation to meet our legal, statutory and contractual obligations and toprovide you with our products and services. We will never collect anyunnecessary personal data from you and do not process your information in anyway, other than as specified in this notice.

We may collect, use, store and transfer differentkinds of personal data about you which we have grouped together as follows:

‍Identity Data - Includes first name, lastname, name of school.
Contact Data - Includes email address andtelephone numbers.‍
Technical Data - Includes internet protocol(IP) address, your login data, browser type and version, time zone setting andlocation, browser plug-in types and versions, operating system and platform andother technology on the devices you use to access this website.‍
Profile Data - Includes your username andpassword, preferences, feedback and survey responses.‍
Usage Data - Includes information about howyou use our website, products and services.‍
Marketing and Communications Data - Includes your preferences inreceiving marketing from us and our third parties and your communicationpreferences.

We do not collect any Special Categories of Personal Data about you (this includesdetails about your race or ethnicity, religious or philosophical beliefs, sexlife, sexual orientation, political opinions, trade union membership,information about your health and genetic and biometric data). Nor do wecollect any information about criminal convictions and offences.

How we collect that Information:

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

Direct interactions. You may give us yourIdentity / Contact data by filling in forms or by corresponding with us bypost, phone, email or otherwise. This includes personal data you provide whenyou:

apply for ourproducts or services
create an account onour website
subscribe to ourservice or publications
request marketing tobe sent to you
give us some feedbackor complete a survey

Automated technologies or interactions. As you interact with our website, we may automatically collectTechnical Data about your equipment, browsing actions and patterns. We collectthis personal data by using cookies, server logs and other similartechnologies.

Cookies.
Our website uses cookies. A cookie is a small text file stored in your computercontaining text data. We use cookies for certain functions to improve theusability of the website. However, enabling cookies in your web browser isnecessary if you wish your selections to be remembered for future visits on thesame computer. You can set your browser to refuse all or some browser cookies,or to alert you when websites set or access cookies. For more information aboutcookies and instructions on how to adjust your browser settings to restrict ordisable cookies, see the IAB website at www.allaboutcookies.org. If you disableor refuse cookies, please note that some parts of this website may becomeinaccessible or not function properly. For more information regarding cookiesand our website, please read our cookie policy here.

Third parties or publicly available sources.
We may receive personal dataabout you from various third parties, including technical data from thefollowing parties:

analytics providers[such as Google based outside the EU]
advertising networks[such as Google based outside the EU]
search informationproviders [such as Google based outside the EU].

Third-party links.
This website may include links tothird-party websites, plug-ins and applications. Clicking on those links orenabling those connections may allow third parties to collect or share dataabout you. We do not control these third-party websites and are not responsiblefor their privacy statements. When you leave our website, we encourage you toread the privacy notice of every website you visit.

How We Use Your Personal Data (Legal Basis forProcessing)

The Brownlee Foundation takes your privacy veryseriously and will never disclose, share or sell your data without yourconsent; unless required to do so by law. We only retain your data for as longas is necessary and for the purpose(s) specified in this notice. Where you haveconsented to us providing you with promotional offers and marketing, you arefree to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailedbelow: -

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To perform our services to you including:	· Identity · Contact · Marketing and Communications	· Performance of a contract with you
Registering you for events Sending out key information related to events	· Identity · Contact · Marketing and Communications	· Performance of a contract with you
To manage our relationship with you which will include:	· Identity · Contact · Profile · Marketing and Communications	· Performance of a contract with you · Necessary to comply with a legal obligation · Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Notifying you about changes to our terms or privacy policy Asking you to leave a review or survey	· Identity · Contact · Profile · Marketing and Communications	· Performance of a contract with you · Necessary to comply with a legal obligation · Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to complete a survey	· Identity · Contact · Profile · Usage · Marketing and Communications	· Performance of a contract with you · Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	· Identity · Contact · Technical	· 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 reorganization or group restructuring exercise) · Necessary to comply with a legal obligation
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	· Technical · Usage	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)
To make suggestions and recommendations to you about goods or services that may be of interest to you	· Identity · Contact · Technical/Usage · Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

Your Rights

You have the right to access any personal informationthat The Brownlee Foundation processes about you and to request informationabout: -

What personal data we hold about you
The purposes of the processing
The categories of personal data concerned
The recipients to whom the personal data has/will be disclosed
How long we intend to store your personal data for
If we did not collect the data directly from you, information about thesource

If you believe that we hold any incomplete orinaccurate data about you, you have the right to ask us to correct and/orcomplete the information and we will strive to do so as quickly as possible;unless there is a valid reason for not doing so, at which point you will benotified.

You also have the right torequest erasure of your personal data or to restrict processing (where applicable) in accordance with thedata protection laws; as well as to object to any direct marketing from us.Where applicable, you have the right to data portability of your informationand the right to be informed about any automated decision-making we may use.

If we receive a request from you to exercise any ofthe above rights, we may ask you to verify your identity before acting on therequest; this is to ensure that your data is protected and kept secure.

Sharing and Disclosing Your Personal Information

We do not share or disclose any of your personalinformation without your consent, other than for the purposes specified in thisnotice or where there is a legal requirement.

Safeguarding Measures

The Brownlee Foundation takes your privacy seriouslyand takes every reasonable measure and precaution to protect and secure yourpersonal data. We work hard to protect you and your information fromunauthorised access, alteration, disclosure or destruction and have severallayers of security measures in place.

Transfers Outside the EU (if applicable)

The Brownlee Foundation utilise some productsor services (or parts of them) thatmay be hosted/stored in non-EU countries,which means that we may transfer any information which is submitted by youthrough the website outside the European Economic Area ("EEA") forthe below purposes: -

Google, Dropbox, Website hosting etc

Therefore, when you use our website/send us an emailetc, the personal information you submit may be stored on servers which arehosted in non-EU countries. Wherethis is the case, we will take steps to ensure that those providers use thenecessary level of protection for your information and abide by strictagreements and measures set out by The Brownlee Foundation to protect your data and comply with the relevant data protectionlaws.

Consequences of Not Providing Your Data [if relying onstatutory/contractual requirement basis]

You are not obligated to provide your personalinformation to The Brownlee Foundation, however, as this information isrequired for us to provide you withour services and legitimate interests, we will not be able to offer some/allour services without it.

Legitimate Interests [if applicable]

As noted in the ‘HowWe Use Your Personal Data’ section of this notice, we occasionally processyour personal information under the legitimate interests’ legal basis. Wherethis is the case, we have carried out a thorough Legitimate Interests’Assessment (LIA) to ensure that we have weighed your interests and any riskposed to you against our own interests; ensuring that they are proportionateand appropriate.

How Long We Keep Your Data

The Brownlee Foundation only ever retains personalinformation for as long as is necessary and we have strict review and retentionpolicies in place to meet these obligations. The personal information submittedwill be retained for a minimum of 5 years or until the Brownlee Foundation nolonger offers its events service after which time it will be destroyed. Whereyou have consented to us using your details for direct marketing, we will keepsuch data until you notify us otherwise and/or withdraw your consent.

Lodging A Complaint
The Brownlee Foundation onlyprocesses your personal information in compliance with this privacy notice andin accordance with the relevant data protection laws. If, however you wish toraise a complaint regarding the processing of your personal data or areunsatisfied with how we have handled your information, you have the right tolodge a complaint with the Information Commissioner’s Office (ICO), the UKsupervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to dealwith your concerns before you approach the ICO so please contact us in thefirst instance.

The BrownleeFoundation

Mr Chris Smith
1 London Road
Ipswich
IP1 2HA
01473 229800

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