Who are we?
Stretching the City Limited (“We”) are committed to protecting and respecting your privacy.
This policy, together with our terms and conditions (https://stretchingthecity.com/terms-conditions/) and any other documents referred to on it, sets out the basis on which any personal data we collect from you, or that you provide to us, whether via this website or otherwise, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
This policy applies to the personal data of our website users, clients, suppliers and anyone else external to our business.
For the purpose of UK and European data protection and e-privacy legislation (Data Protection Legislation), the data controller is Stretching the City Limited whose registered office address is C/o The Bell House, 57 West Street, Dorking, Surrey, RH4 1BS
Information we collect from you
We will collect and process the following data about you:
Information you give us.
This is information about you that you give us by filling in forms on our website www.stretchingthecity.com (our website) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you make an enquiry, sign up to our newsletter and engage with us to provide services (subject to our terms of business, (https://stretchingthecity.com/terms-conditions/) participate in discussion boards or other social media functions on our website, respond to a survey, supply goods or services to us and when you report a problem with our website.
The information you give us may include your name, position, company, contact details (such as address, e-mail address and phone number).
Information we collect about you.
With regard to each of your visits to our website we will automatically collect the following information:
Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), services, job category or employers you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
Information we receive from other sources.
This is information we receive about you from other sources. We are working closely with third parties (including, for example, business partners, sub-contractors in technical services, analytics providers, search information providers). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.
Legal grounds for collection and use of your personal information
We will only collect, use and otherwise handle your personal information when:
We have your consent for specified, explicit and legitimate purposes (see section 5); and/or
It is necessary for our legitimate interests in connection with operating the website and our business, in particular:
Responding to your queries;
Carrying out direct marketing (to develop our products/services and grow our business);
Providing services and/or information to you;
Hosting and maintaining our website, including trouble shooting, data analysis, testing, system maintenance, support, reporting and hosting of data (for running our business, provision of administration and IT services, network security, to prevent fraud);
Collecting and recovering money owed to us;
Notifying you of changes to our terms or privacy policy (to keep our records updated and to study how customers use our services);
Asking you for a review or take a survey (to keep our records updated and to study how clients use our services;
For the establishment, exercise or defence of a legal claim;
Preventing and detecting fraud and other criminal offences; and/or
Ensuring network and information security,
As long as, in each case, these interests are in line with applicable law and your legal rights and freedoms; and/or
Where this is necessary for legal obligations which apply to us; and/or
Where this is necessary for the performance of a contract we have with you (for example to provide goods and/or services to you) or that you have with a third party; and/or
Where this is necessary to take steps at your request prior to entering into a contract.
Uses made of the information
We use information held about you in the following ways:
Information you give to us. We will use this information:
To carry out our obligations arising from any contracts entered into between you and us, respond to your queries and to provide you with the information and services that you request from us;
Where you have provided us with your contact details, to provide you with information about services we feel may interest you. This may be by post, telephone or electronic means (e-mail). If you are an existing client, a client who has enquired about our services where you have previously engaged with us, we will only contact you by electronic means (e-mail) with information about services similar to those when you previously engaged with us. If you do not want us to use your data in this way, please use the opt out link in the acknowledgement email we will send you when we first take your details which gives you the opportunity to opt out. If you opt out of marketing communication, your use of our services and visit to and use of the website will not be affected;
Marketing Opt-Out – you are entitled to opt-out of marketing communication at any time and free of charge by using the “unsubscribe”option included in any marketing e-mail or other marketing material received from us. To notify you about changes to our service;
To ensure that content from our website is presented in the most effective manner for you and for your computer.
We may also use any personal information that you provide to us:
Where legally permitted for specific purposes made clear at the point of collection; and/or
Where we otherwise have legal grounds for collection and use of your personal information as explained in more detail in clause 4.
If you choose not to provide personal information requested by us, we may not be able to provide you with the information and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the personal information. Aside from this, your visit to the website will remain unaffected.
Information we collect about you. We will use this information:
To administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
To improve our website to ensure that content is presented in the most effective manner for you and for your computer.
Information we receive from other sources.
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive), where those purposes are compatible.
Disclosure of your information
Some services that we provide require the involvement of third parties. We have carefully selected these third parties and taken steps to ensure that your personal information is adequately protected.
You agree that we have the right to share your personal information with the following third parties:
i) Sharing with our service providers
We may share your personal information with our third party service providers based in the UK or the European Economic Area (“EEA”) who we engage to process the information that we collect from you on the website or otherwise, and/or to host and maintain our website, content or services, on our behalf and in accordance with this privacy policy.
We will let you know if we need to transfer your personal information to any third party service providers located outside of the EEA in addition to service providers mentioned in clause 8.
Where we employ third party companies or individuals to process personal information provided by us (and not collected by them), they only use this personal information on our behalf and in line with our instructions and this privacy policy.
ii) Sharing with other selected third parties
We will disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If Stretching the City Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
Where we will transfer personal data to a third country we will ensure that the third country concerned has adequate legal protections in place for your personal data. If not, we will put EU Commission approved model clauses in place and make these available to you on request to info@stretchingthecity.com
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or our terms and conditions of business (available on request from info@stretchingthecity.com) and other agreements; or to protect the rights, property, or safety of Stretching the City Limited, our customers, or others. This includes exchanging information with other companies and organisations, regulators and law enforcement agencies for the purposes of preventing and detecting fraud, other criminal offence, credit risk reduction and/or to ensure network and information security.
How long do we store personal information?
It is our policy to retain your personal information for the length of time required for the specific purpose or purposes for which it was collected, which are set out in this privacy policy. We will keep your personal information for 7 years. However, on occasions we may be obliged to store some data for a longer time, for example, where a longer time period is required by applicable laws. In this case, we will ensure that your personal data will continue to be treated in accordance with this privacy policy.
For more information on how long cookies are stored, please refer to our cookie policy.
Where we store your personal data
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
All information you provide to us is stored on secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data or when you receive our welcome email. You can also exercise the right at any time by contacting us at info@stretchingthecity.com.
Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. 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.
If you wish to:
Access, confirm, correct, rectify, update, supplement, anonymise, block, restrict or delete your personal information;
Object to our use of your personal information;
Withdraw your consent;
If you have any questions about our processing of your personal information; or
If you would like to transfer your personal information from us to another person or business,
please contact us at info@stretchingthecity.com
Where you request access to your personal information, the information will be provided in writing. In order to comply with your request, we may ask you to verify your identity. We will fulfil your request by sending your copy electronically, unless the request expressly specifies a different method. For any subsequent access request, we may charge you an administrative fee.
We will provide you with all rights in relation to your personal information to which you are entitled under applicable law. If you are unhappy with the way that we have handled your personal information, you can make a complaint to the authority responsible for data protection in the country that you are based. Contact details are typically available online, or alternatively you may ask us for assistance info@stretchingthecity.com. In the UK the data protection authority is the Information Commissioner’s Office (ICO), tel 0303 123 1113, website www.ico.org.uk. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to our privacy policy
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@stretchingthecity.com
Issue 3
November 2020