Privacy Policy (Including Cookie Policy)
1. Introduction
We respect your right to privacy and are committed to safeguarding it. This privacy policy sets out details of the information we may hold on you, how we use that information and your rights.
This policy should be read alongside our Terms and Conditions, which governs the use of the platform.
2. About us
We are Acorn an SPV (Special Purpose Vehicle) partnership between, Sacyr Infrastructure UK Ltd, Kajima Partnerships Ltd and Aberdeen (ABRDN Plc) and are the data controllers and processors of your personal data.
We are supported by Sacyr UK Ltd registered in England and Wales with company number 11031255 whose registered office is 1 Lyric Square (Office 2.13), London, England, W6 0NB who are data processors of your personal data.
And
The Business Centre (trading as P-Digital) Gloucester Limited is a company registered in England & Wales with company number 03816550 whose registered office is at Unit 3, Ambrose House, meteor Court, Barnett Way, Barnwood, Gloucester GL4 3GG who are data processors of your personal data.
If you have any questions about your personal information or our privacy policy, please contact us at privacy@newvelindre.info
3. What is personal data
Your personal data is information which, by itself or with other information available to us, can be used to identify a person directly or indirectly.
Some personal data is categorised as 'sensitive personal data' and includes information about race, ethnic origin, political opinions, religious beliefs, mental or personal health, sexual life or orientation, criminal proceedings (either alleged or prosecuted) and membership of a trade union.
We do not consider personal information to include information that has been anonymised or aggregated so that it can no longer be used to identify a person, whether in combination with other information or otherwise.
The collection and use of your personal data is regulated under the UK Data Protection Act 1998 (the Act) and the 2018 General Data Protection Regulations (GDPR) and we process your data in accordance with these regulations as both a data controller and a data processor.
For more information on personal data you can view the information provided by the Information Commissioners Office (ICO): https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/personal-information-what-is-it/what-is-personal-data/what-is-personal-data/
4. How do we collect your information?
We collect information from the following sources:
Directly from you with your explicit consent
Our lawful basis of processing your information; By using this site and sending us communications you have expressed your consent for us to process, store and use your data in line with this policy and applicable legal regulations.
We may process your personal information, specifically data related to IP address, website visits and navigation behaviour data, with the lawful basis of legitimate interest, understood as our interest in administering the website and providing related services in conjunction with the website.
For more information on Lawful Basis, you can view the information provided by the ICO. https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/lawful-basis/a-guide-to-lawful-basis/#what
5. What information do we collect?
We may collect, store, and use the following kinds of personal information:
Data and reason:
- Name (Mandatory)
To provide you with account on the platform - Email Address (Mandatory)
To provide you with account on the platform - Postcode (Mandatory)
To able to provide locally appropriate services on the platform - Equality, Diversity & Inclusion demographics Optional or ability to select "prefer not to say"
To help us monitor the impact we are having within our communities, and particularly for protected or under-represented communities in order to provide meaningful impact to those with additional or complex needs - Phone number (Optional)
In order to provide you with services in which you have expressed an interest as a means to contact you to deliver the services - Information provided to us through forms within the platform (Optional)
In order to provide you with services in which you have expressed an interest as a means to contact you to deliver the services
Legal Basis as set out in Article 6 of the UK GDPR
(a) Consent: the individual has given clear consent for process their personal data for a specific purpose. Consent will be always the legal basis when we collect optional sensitive data should you decide to enter it.
and
(f) Legitimate interests: the processing is necessary for legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect the individual's personal data which overrides those legitimate interests.
We may also collect information with the purpose of investigating the communications you send us if it is deemed necessary
We may collect data relating to your visits to the website that cannot easily identify you but records your use of our website, online courses and content including IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths.
If you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information.
6. How do we use your information?
Personal information submitted to us via this website will be used for the purposes outlined below or in relevant parts of the website. We may use your personal information to:
- Manage the website
- Send you email or phone notifications which you have specifically requested, particularly those related to the Contact Us page
- Provide third parties with statistical information about our website users. This information will be anonymised and not used to identify any individual users
- Deal with enquiries and complaints that may be about you, relating to this website or your use of it
Where you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the license you grant us.
7. How long do we retain your data?
We will only retain your personal information for as long as is necessary to fulfil the purposes we collected it for.
To determine the appropriate retention period for the personal information we hold, we consider the amount, nature and sensitivity of the personal information, the risk of harm from unauthorised use or disclosure of your personal information, the reasons why we handle your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
We may retain your data for the following reasons:
- In order to establish, exercise or defend our legal rights
- If we believe the documents may be relevant to any ongoing or prospective complaint or legal proceedings
- The purpose of satisfying any legal or accounting requirements
If you require further information about our specific retention periods, please contact us at contact@newvelindre.info
8. Ways you can access and control your personal information
Under data protection laws you have legal rights concerning our usage of your personal information, including:
- You have the right to know what personal information we hold on you.
- You have the right to ask us to correct or complete inaccurate or out of date personal information
- You have the right to object to our processing all or part of your personal information.
- Where we are relying on your consent to process data, you have the right to withdraw your consent
- You have the right to object to decisions taken by automatic means without human intervention
- You have the right to request that some elements of your information, such as academic progress, be provided to other organisations.
- You have the right to complain if you are unhappy with our handling of your data.
Please be aware that if you ask us to cease processing all or part of your data, this will impact on your ability to access some of our services. Further, we can only comply if there is no legitimate reason for us to continue to process your personal data.
We will honour any statutory right you might have to access, modify or erase your personal information. We encourage you to make such a requesting a "Subject Access Request" via email to privacy@newvelindre.info
If you wish to make a complaint, you should first contact us via privacy@newvelindre.info to reach our Data Protection Officer. You can also submit a complaint to the Information Commissioner's Office; further details can be found at www.ico.org.uk.
9. How do we share your data?
We may share your personal information:
- With your consent
- To the extent that we are required by law to do so
- In connection with any legal proceedings or prospective legal proceedings
- To establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
If any of the above occurs, we shall inform you of any such disclosure if lawfully permitted to do so. Except as stated in this privacy policy we will not provide your information to third parties.
Additionally, we could send your data to collaborators who provide services, such as IT and web maintenance, legal services, and administrative agencies that, in connection with the provision of their services, access Sacyr's personal data, which could be a data controller or a data processor.
We carry out a selection and control process with the third parties which we have signed data protection agreements, where they follow a series of obligations in terms of data protection. Other than the above assumptions, we do not communicate your personal data to any additional third party.
If any of our service providers which are personal data processors are located outside the UK or the EU, we shall adopt all measures that are applicable in accordance with the regulations designed to ensure the proper transfer of personal data to third party countries or international organisations.
10. International data transfers
Your information will be stored on servers located within the UK and Spain. We may disclose information about you to any of our employees, officers, agents, suppliers, or subcontractors, in so far as reasonably necessary for the purposes as set out in this privacy policy. As such all parties are obliged to treat your information in accordance with the scope of your consent and the law, in line with their contracts with us.
11. Security Measures
We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
Our data warehouse and servers use the latest technologies and robust procedures to ensure data security and safety. Our servers will be compliant with ISO 9001 and ISO 27001, the highest security and quality assurance standards in the UK for data storage and transmission.
12. Cookies
Our Cookie Policy, which sets out how we use cookies to distinguish you from others on our site and provide you with a good user experience
The platform uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
You may choose to refuse cookies but, if you do so, some of the functionality of the Website or Online Courses may no longer be available to you.
13. Updating this Privacy Policy
We may update this Privacy Policy from time to time to comply with law or to meet the requirements of our business as they progress.
You will be notified through email of all changes as they occur including the contents of changes and the date(s) they will become effective.
The Privacy Policy will be amended accordingly on our website, and your continued access and use will be subject to any changes.
14. Contacting us
You can contact us by email, using privacy@newvelindre.info or contact@newvelindre.info