Privacy
Policy

1. INTRODUCTION


The Difference Collective (referred to as “we”, “us” or “our” in this privacy notice) is the data controller responsible for your personal data
This privacy notice explains how, when and why we collect and process individuals’ data.

Contact Details
Our full details are:
The Difference Limited (Company number 10609705)
hello@thedifferencecollective.com
The Old Rectory, Church Street, Weybridge, Surrey, England, KT13 8DE
+44 (0) 3302 230 646

2. DATA WE COLLECT ABOUT YOU, THE PURPOSE OF COLLECTING IT AND THE REASONS FOR PROCESSING IT

 
Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process the following categories of personal data about you:
  • Communication Data includes any communication you send us, whether through the contact form on our website, email, text, social media messaging, social media posting or any other communication. We process this data for the purposes of communicating with you, record-keeping and the establishment, pursuance or defence of legal claims. Our lawful grounds for this processing are our legitimate interests, which, in this case, are administering and growing our business.
  • Customer Data includes data relating to any purchases of services, such as your name, title, billing address, email address, phone number, contact details and financial information. We process this data to supply services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps to enter into such a contract at your request.
  • Member Data includes data relating to prospective and current Collective members, such as your name, title, address, email address, phone number, contact details, work history, photograph and bank details. We process this data to ensure onboarded members meet the Collective requirements and so that we can effectively match members with work opportunities. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps to enter into such a contract at your request.
It is very important that the information we hold about you is accurate and up to date. Please let us know if your personal information changes at any time by emailing us at hello@thedifferencecollective.com or by adjusting your preferences using the link in any of our marketing emails.
  • User Data includes data about how you use our website and any online services and any data you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests, which, in this case, enable us to administer our website and our business properly.
  • Technical Data includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, administer and protect our business and website, deliver relevant website content and advertisements to you and understand the effectiveness of our advertising.
    Our lawful grounds for this processing are our legitimate interests, which, in this case, enable us to administer our website and our business properly, decide our marketing strategy and grow our business.
  • Marketing Data includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions, such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests, which are to study how customers use our products/services, develop them, grow our business and decide our marketing strategy.
We may use Customer Data, Member Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is our legitimate interest which is to grow our business.
We may also use such data to send other marketing communications to you. Our lawful grounds for this processing are either consent or legitimate interests (namely, to grow our business).
Where we are required to collect personal data by law or under the terms of the contract between us, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver services to you or onboard you as a member). If you don’t provide us with the requested data, we may have to cancel a service you have ordered or decline your membership application: if we do, we will notify you at that time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information, please email us at hello@thedifferencecollective.com. If we need to use your details for a new purpose, we will let you know and explain the legal grounds for processing. We may process your personal data without your knowledge or consent where this is required or permitted by law. We do not carry out automated decision-making or profiling.
Sensitive Data
Sensitive data 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. We collect sensitive data from our members for monitoring equity and inclusion purposes. Our lawful grounds for collecting and processing this data are our legitimate interest, which in this case is advancing diversity and inclusion, and consent. We do not collect any Sensitive Data for any other purposes.

3. HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example, by filling in forms on our site or by sending us emails). We may automatically collect certain data from you using cookies and similar technologies as you use our website.
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU and search information providers such as Google based outside the EU. We may also receive data from publicly available sources such as Companies House based inside the EU.

4. MARKETING COMMUNICATIONS

Our lawful ground for processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely, to grow our business). Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our services or (ii) you agreed to receive marketing communications, and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
We will get your express consent before sharing your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at hello@thedifferencecollective.com at any time. If you opt out of receiving marketing communications, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations, etc.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:
  • Members of The Difference Collective
  • Suppliers to The Difference Collective – including but not limited to designers and videographers
  • Service providers who provide IT and system administration services.
  • Professional advisers, including lawyers, bankers, auditors and insurers
  • Government bodies that require us to report processing activities.
We require all third parties to whom we transfer your data to respect the security of your personal data and treat it according to the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Countries outside the European Economic Area (EEA) sometimes offer different levels of protection to your personal data, so European law has prohibited transfers of personal data outside the EEA unless the transfer meets certain criteria. Many of our third-party service providers are based outside the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
  • We will only transfer your personal data to countries the European Commission has approved as providing adequate protection for personal data.
  • Where we use certain service providers, we may use specific contracts, codes of conduct or certification mechanisms approved by the European Commission, which give personal data the same protection it has in Europe.
  • If we use US-based providers that are part of the EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to members, partners, and suppliers who have a business and need to know such data. They will only process your personal data on our instructions and must keep it confidential.

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

8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements.
When deciding how long to keep data, we consider its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, processing purposes, whether these can be achieved by other means and legal requirements.
For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease to be customers.
In some circumstances, we may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice.

9. YOUR LEGAL RIGHTS

Under data protection laws, you have rights regarding your personal data, including the right to request access, correction, erasure, restriction, transfer, object to processing, request data portability, and (where the lawful ground of processing is consent) withdraw consent.
You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at hello@thedifferencecollective.com.
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 or refuse to comply with your request if your request is unfounded, repetitive or excessive.
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 security measure ensures that personal data is not disclosed to anyone with no right to receive it. We may also contact you to ask you for further information about your
request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues(www.ico.org.uk). We would be grateful if you would contact us first if you have a complaint so we can try to resolve it for you.

10. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking or enabling those links may allow third parties to collect or share your data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. COOKIES

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