Privacy Policy

Introduction

Your privacy is important to us, so to:

  • Let you know about your privacy rights;
  • How the law protects you, and
  • Enable you to understand how Manchester Three Rivers looks after your personal data

We have prepared this Privacy Policy. Please use the guide to specific sections below to easily find what you are looking for.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW AND WHY WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. DATA SECURITY
  7. DATA RETENTION
  8. YOUR LEGAL RIGHTS

 

  1. Important information and who we are

Purpose of this privacy notice

Our privacy notice aims to give you information on how Manchester Three Rivers collects and processes your personal data through your use of our website and related services, including any personal data you may provide through this website when you subscribe with us or purchase our products.

Given the nature of our services, we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other notices we may provide you so that you are fully aware of how and why we are using your data. This privacy notice does not override our other notices and may be updated from time to time.

Data Controller

Manchester Three Rivers control and are responsible for the personal data that we hold about you. Our company correspondence details and registered company number are included on our website http://www.manchesterthreerivers.com.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

We would appreciate the chance to deal with any data protection concerns so please contact us at data@manchesterthreerivers.com in the first instance.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

Changes to the privacy notice and your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website does not contain any third-party links.

  1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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

  • Identity Data includes first name, last name or similar identifier.
  • Contact Data includes billing address, email address and telephone numbers.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us, which includes anything we’ve sent or delivered to you.
  • Technical Data includes details of visits to our site, internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data purchases or orders made by you, your interests, preferences, feedback, communications you’ve sent to us or we’ve sent to you.
  • Usage Data includes information about how you use our website, communications (including email and social media), products and services.

 

  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect and use Aggregated Data such as statistical 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.

We do not usually collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. In some circumstances, we may inadvertently record Special Categories of Personal Data if voluntarily disclosed to us in email or over the phone. Under such circumstances, any Special Categories of Personal Data will be treated in accordance with your rights.

If you fail to provide personal data

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 we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  1. How is your personal data collected?

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

  • Direct correspondence. You may give us your Identity, Contact and/or Financial Data by contacting us via social media, our website, post, phone, text, email or otherwise. This includes personal data you provide when you:
  • Subscribe to our service;
  • Request marketing to be sent to you;
  • Subscribe to a promotion; or
  • Communicate with us, whether it’s giving us some feedback, asking us any questions or providing us with any suggestions about our products and services.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your browsing actions and patterns.

 

 

  1.  How and why we use your personal data

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

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is in our legitimate interests and your interests do not override that interest.
  • Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message from us. You have the right to withdraw consent to marketing at any time by unsubscribing, or by contacting us.

The points below set out how we use your data and the lawful basis for doing so.

Activity:

To register you as a subscriber as requested by you:

Data required:

(a) Identity,

(b) Contact,

Activity:

To process and deliver your order including:

(a) Manage payments, fees and charges,

(b) Collect and recover money owed to us

Data required:

(a) Identity,

(b) Contact,

(c) Financial,

(d) Transaction,

(e) Marketing and Communications

Activity:

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy,

(b) Asking you to leave a review or take up one of our services

Data required:

(a) Identity,

(b) Contact,

(d) Marketing and Communications

Data required for:

(a) Performance of a contract with you,

(b) Necessary to comply with a legal obligation,

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

Activity:

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Data required:

(a) Identity,

(b) Contact,

(c) Technical

Data required for:

(a) 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 reorganisation or group restructuring exercise),

(b) Necessary to comply with a legal obligation

 

Activity:

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Data required:

(a) Identity,

(b) Contact,

(c) Profile,

(d) Usage,

(e) Marketing and Communications,

(f) Technical

Data required for:

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Activity:

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Data required:

(a) Technical,

(b) Usage

Data required for:

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)

 

 

Activity:

To make suggestions and recommendations to you about goods or services that may be of interest to you on the basis of previous sales to you via electronic means (telephone, email, SMS or App push notifications)

Data required:

(a) Identity,

(b) Contact,

(c) Technical,

(d) Usage,

(e) Profile,

Data required for:  

Necessary for our legitimate interests (to develop our products/services and grow our business)

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Promotional offers from us  

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you subscribed and, in each case, you have not opted out of receiving that marketing.

Third-party marketing  

We will get your express opt-in consent before we share your personal data with any company outside of Manchester Three Rivers for marketing purposes.

Opting out

You can ask us to stop sending you marketing and promotional messages at any time by unsubscribing or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase. We will continue to communicate with you for reasons essential to the fulfilment of any orders (this includes information relating to your account and deliveries), you cannot opt out of any such messages.

Change of purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. Disclosures of your personal data
  • We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4.
  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers based who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit third parties to process your personal data for specified purposes and in accordance with our instructions. Should a Third Party contact you for a purpose within the bounds of this policy those communications will be covered by the third party’s privacy policy.

  1. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

 

  1. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

In some circumstances you can ask us to delete your data: see ‘Request Erasure’ below for further information.

For Personal Data that is not required to be kept for legal purposes or where our legitimate interest is not overridden by your interests or fundamental rights and freedoms, we will retain your data for 24 months from the point at which you cancel your subscriptions with us and stop all interaction with Manchester Three Rivers.  If you have opted into receiving marketing messages from us, we will notify you via email prior to deleting your Personal Data so you have a chance to prevent the deletion and enable you to retain access to our offers.

If you have opted out of marketing, please be aware that we will delete your Personal Data in accordance with the timeframes above without further notification to you.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, these include:

  • 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.

 

If you wish to exercise any of the rights set out above, please contact us at data@manchesterthreerivers.com. You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide

 

certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

No fee usually required

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.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

Time limit to respond

We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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