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POSITIVE CHANGES (SCOTLAND) CIC PRIVACY POLICY & COOKIE POLICY

Positive Changes (Scotland) CIC respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.

IMPORTANT INFORMATION AND WHO WE ARE
This privacy policy aims to give you information on how Positive Changes (Scotland) CIC (trading as Grace Chocolates) collects and processes your personal data when you provide it to us through the use of our website, when you attend our events, participate in our programmes, volunteer with us, work for us, use our services, or when you purchase products from Grace Chocolates.It is important that you read this privacy policy carefully so that you are fully aware of how and why we are using your data.We collect, use and are responsible for certain personal data about you. When we do so we are subject to data protection laws applicable in the United Kingdom and we are responsible as ‘controller’ of that personal data for the purposes of those laws.

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 may include links to third-party websites, plug-ins and applications (e.g. Facebook, Twitter or Instagram). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our website, we encourage you to read the privacy policy of every website you visit.

KEY TERMS

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means freely given, specific, informed and unambiguous indication of a data subject’s wishes which is indicated by a positive action.
External Third Parties means:
a. Service providers acting as processors based within the UK  who provide IT, payroll services and system administration services.
b. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the UK  who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
Legitimate Interest means the interest of our organisation in conducting and managing the organisation to enable us to promote the organisation’s values and provide the best service to service users, customers purchasing our products, staff, volunteers and donors. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
We, us, our, or Grace Chocolates means Positive Changes (Scotland) CIC, a community interest company (registered number SC577043) and having its registered office at 12 Keir Street, Bridge of Allan, Stirling, FK9 4NW.

THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where it is no longer possible to identity the person (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, maiden name, last name, or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account details of staff (and customers, when processing any refunds).
  • Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
  • Technical Data includes 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 our website.
  • Usage Data includes information about how you use our website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
  • Sensitive Personal Data includes data concerning health.

HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity Data, Financial Data, and Contact Data by filling in forms on our website or by corresponding with us by post, phone, email, in person or otherwise. This includes personal data you provide when you:
  • purchase products from our website;
  • apply to be a volunteer or apply for employment;
  • donate to us;
  • subscribe to our mailing list or ask to receive marketing communications; or
  • use our services.
  • Third parties. We may receive personal data about you from various third parties as set out
    below:
  • Identity Data from the following par

HOW 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 necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where you have given us specific and informed consent.

See section 1.3 of this policy above find out more about the types of lawful basis that we will rely on to process your personal data.

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. You have the right to withdraw consent to marketing at any time by contacting us, for our contact details, see section 13 of this policy below.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on

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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

PURPOSE/ACTIVITY TYPE OF DATA LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
To enable you to:
(a)  purchase our products through our website;
(b)  volunteer or work with us;
(c) attend and participate in our events;
(d) donate to us; and
(e) use our services.		 (a) Identity
(b) Contact
(c) Financial
(d) Transaction (e) Marketing and Communications		 (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to raise awareness of reoffending in the Scottish Criminal Justice System, to prevent and reduce further reoffending by supporting the rehabilitation and reintegration of women on their release from prison by providing work experience and formal qualifications)
(c) Consent
(a) To allow you to sign up for our mailing list, or, remove you where you no longer wish to receive our updates
(b) To invite you to our events or send other marketing communications.		 (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications		 Consent
To manage our relationship with you which will include:
(a) notifying you about changes to our terms or privacy policy.
(b) keeping you updated of the progress of your order and notifying you of any changes or updates to the delivery of your order (where required).		 (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications		 (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)
To administer and protect our organisation and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical		 (a) Necessary for our legitimate interests (for running our organisation, provision of administration and IT services, network security, to prevent fraud)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our website, events, products and services and marketing (a) Technical
(b) Usage		 Necessary for our legitimate interests to keep our website updated and relevant, to develop our organisation and to inform our marketing strategy

6. MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing. We will only send you marketing communications when you have given us your express consent. We may use your Identity, Contact, Technical, and Usage Data to form a view on what we think you may want or need, or what may be of interest to you.

You will only receive marketing communications from us if you specifically consented to receive this information from us or purchased goods from us or if you signed up to receive communications from us and, in each case, you have not opted out of receiving that marketing.

OPTING OUT
You can ask us to stop sending you marketing messages by contacting us at any time.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 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.

DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with External Third Parties as set out in section 1.3 of this policy for the purposes set out in the table in section 5 above. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).

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. In addition, we limit access to your personal data to those personnel and other third parties who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

If you would like details of retention periods for different aspects of your personal data you can request these details from us by contacting us using the details provided below.

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.

YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal
data. In particular, you have the following

Access The right to be provided with a copy of your personal data (the right of access)
Rectification The right to require us to correct any mistakes in your personal data
To be forgotten The right to require us to delete your personal data—in certain situations
Restriction of processing The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data
Data portability The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object The right to object:
—at any time to your personal data being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

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.
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.
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 a number of requests. In this case, we will notify you and keep you

HOW TO CONTACT US
Please contact us by post or email if you have any questions about this privacy policy or the information we hold about you using the details are shown below

Our contact details
Positive Changes (Scotland) CIC 12 Keir Street, Bridge of Allan, Stirling, FK9 4NW gracechocolatesuk@gmail.com

CHANGES TO OUR PRIVACY POLICY
This version was last updated in October 2018 and historic versions (if applicable) can be obtained by contacting us at details provided above.

HOW TO COMPLAIN
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.