LAST UPDATED: May 2018

Introduction

1.0 We are committed to safeguarding the privacy of Who Do You Think I Am? website visitors and service users of our
website, and services.

1.1 This privacy policy ( “this policy”) explains how the Who Do You Think I Am? (WDYTIA) website,https://www.whodoyouthinkiam.org, (‘our website’) operated by Who Do You Think I Am.org (“we”, “us” and “our” ) uses and processes any personal information that you provide us, or that we collect from you when you use our website or/and any personal information you provide us and we collect from you offline.

1.2 This policy applies where we are acting as a data controller with respect to the personal data of Who Do You Think I
Am? visitors and service users; in other words, where we determine the purposes and means of the processing of that
personal data.

1.3 We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website or/and explain further options.

1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive subscriptions. You can access subscription options through your profile by logging onto the website.

1.5 In this policy, “we”, “us” and “our” refer to Who Do You Think I Am? For more information about us, see Section 17.

1.6 In this policy, ‘information/materials’ in reference to this website means: any information including post text comments, visual images , video link submission or any other information and content posted or disclosed by you, onto the website’s interactive features

1.7 In this policy interactive features in reference to this website means: Discussion Board, Story Chain, Opinion Polls and Dream Lounge.

1.8 In this policy, where not specified within a specific category for processing, “Personal data” is defined in Article 4(1) of the GDPR:
“(1) ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How we use your personal data

2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.

2.2 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3 We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you. The account data may be processed may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent, implied, and expressed by the action of signing up and going through the full registration process on our website.

2.4 We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, email address, profile pictures, gender and biographical information- if you have provided it. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent, implied, and expressed by the action of signing up and going through the full registration process on our website.

2.5 We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include the method, nature and description of how you use our interactive features on our website. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.6 We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent, implied, and expressed by the affirmative action of you providing information and materials on our interactive features on our website.

2.7 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent, implied and expressed in the affirmative action of your asking of the enquiry.

2.8 We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers when this is requested. The legal basis for this processing is consent, implied and expressed in the affirmative action of the continuous customer relationship and continuous use of our services.

2.9 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.

2.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent, by you consenting to the processing and collecting as specified.

2.11 We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

2.12 We may process and collect information that you have provided us offline, person to person, or at an event: either hosted by us or at a third-party event (“offline data”). This data may include personal information, which may include: your name, email address, contact telephone details, address, gender and biographical information. The source of this data is you. This data may be processed for the specific reason given and consented by you, this may include the action of adding your details to our email notifications or newsletter, or/and contacting you by email/method specified by you for the purpose gaining further information of WDYTIA for a specific reason given and consented by you. The legal basis for this processing is consent, by you consenting to the processing and collecting as specified.

2.13 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.14 We may process any of your personal data identified in this policy where necessary for [the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.15 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

2.16 Please do not supply any other person’s personal data to us, unless we prompt you to do so.

Providing your personal data to others

3.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

3.2 We are, for the necessary operation of our website, hosted by a web service provider, which provides services and technologies to allow our website to be viewed on the internet, which may involve the processing and access of/to your personal data. Our web service provider is 34sp. You can find information about them here https://www.34sp.com

3.3 Financial transactions relating to our website and services are handled by our payment services
providers, PayPal. We will share transaction data with our payment services providers only to the
extent necessary for the purposes of processing your payments, refunding such payments and
dealing with complaints and queries relating to such payments and refunds. You can find
information about the payment services providers’ privacy policies and practices at
“https://www.paypal.com

3.4 In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure

International transfers of your personal data

4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

4.2 The hosting facilities for our website, 34sp.com, are situated in United Kingdom, with your personal data remaining in the United Kingdom.

4.3 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

Retaining and deleting personal data

5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

5.3 We will retain your personal data as follows:

(a) “Usage data” will be retained on a continuous basis during the time period you have an active account on our website and whilst visiting and using our website, including our interactive features. If you choose to deactivate your account, we will no longer collect usage data. Any usage data that may have been stored prior to deactivation may remain for a period not exceeding six months.

(b) “Account data” will be retained on a continuous basis during the time period you have an active account on our website and whilst visiting and using our website, including our interactive features. You can view your account data by logging on to our website and logging onto your profile and then clicking of you name. If you choose to deactivate your account: by notifying us, your account will be deactivated as soon as possible, not exceeding a period of 28 days, and all your account data will be deleted on our website.

(c) “Profile data” will be retained on a continuous basis during the time period you have an active account on our website and whilst visiting and using our website, including our interactive features. You can view and edit your profile data by logging on to our website and logging onto your profile and then clicking of you name. If you choose to deactivate your account: by notifying us, your account will be deactivated as soon as possible, not exceeding a period of 28 days, and all your profile data will be deleted on our website.

(d) “Service data” your personal data provided in the course of the use of our services will be retained on a continuous basis during the time period you have an active account on our website and whilst visiting and using our website, including our interactive features. You can view your interaction with our interactive features by logging on to our website and logging onto your profile and then clicking of you name. If you choose to deactivate your account: by notifying us, your account will be deactivated as soon as possible, not exceeding a period of 28 days, and all your service data will be deleted on our website.

(e) “Publication data” will be retained on a continuous basis during the time period you have an
active account on our website and whilst visiting and using our website, including our interactive
features. You can view your interaction with our interactive features and all your publication data
that you have personally submitted by logging on to our website and logging onto your profile
and then clicking of you name. You can access edit and delete your publication data from our
discussion forum as part of our interactive features. In respect of personal information contained
within your publication data, we draw you attention to rule 12 of our house rules, which states
“Please be aware of your own safety and the safety of others, by not posting any personal
information about yourself or someone else that is not appropriate for a public forum”. If you
find personal information contained within your publication data you wished for to be removed,
once we are notified (see section 17 for contact details) your requested personal information will
be deleted on our website as soon as possible, not exceeding a period of 28 days. If you choose
to deactivate your account: by notifying us, your account will be deactivated as soon as possible,
not exceeding a period of 28 days, and all your publication data will be deleted on our website.

(f) “Enquiry data” will be retained in relation to the specific enquiry submitted by you for a period not exceeding six months.

(g) “Customer relationship data” will be retained on a continuous basis during the time period you have an active account on our website and whilst visiting and using our website, including our interactive features. If you choose to deactivate your account: by notifying us, your account will be deactivated as soon as possible, not exceeding a period of 28 days, and all your customer relationship data will be deleted on our website.

(h) “Transaction data” will be retained in relation to the specific transaction submitted by you for a period not exceeding six months.

(i) “Notification data” will be retained on a continuous basis during the time period to which you consent. If consent is withdrawn either by unsubscribing or notifying us, you will be unsubscribed and your notification data will cease to be processed and will be deleted from the specific source that you originally consented.

(j) “Correspondence data” will be retained on a continuous basis during the time period you have an active account on our website and whilst visiting and using our website, including our interactive features. If you choose to deactivate your account, we will no longer collect correspondence data. Any correspondence data that may have been stored prior to deactivation may remain for a period not exceeding six months.

(k) “Offline data” will be retained for a specific purpose, consented by you for a specific purpose, retained for a time period specific for the purpose, expressed and explained to you at the time of consent. For example if you have expressed consent to receive our newsletter, your data will be processed as notification data as above.

5.4 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Security of personal data

6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

6.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems. We will store any offline data in a secure , locked filling cabinet.

6.3 The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.

6.4 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.

6.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

6.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).

Amendments

7.1 We may update this policy from time to time by publishing a new version on our website. Any changes to this Privacy Policy will become effective as of the latest “LAST UPDATED’ date.

7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3 We may notify you of significant changes to this policy by email or through the private messaging system on our website.

Your rights

8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.

8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. You can access your ‘publication data’ listing the ‘information and materials’ you have posted on our interactive features by going to our website and clicking on your profile. You can access your ‘profile data’ by going to your profile section when logged into our website.

8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

8.13 You may exercise any of your rights in relation to your personal data by written notice to us OR in addition to the other methods specified in this Section 8.

Third party websites

9.1 Our website includes hyperlinks to, and details of, third party websites.

9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10.

Personal data of children

10.1 Our website and services are targeted at persons over the age of 18

10.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

11.

Updating information

11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.

12.

About cookies

12.1 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.

12.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

12.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

13.

Cookies that we use

13.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website .
(b) status – we use cookies to help us to determine if you are logged into our website.
(c) shopping cart – we use cookies to maintain the state of your shopping cart as you navigate our website.
(d) personalisation – we use cookies to store information about your preferences and to personalise our website for you.
(e) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally
(f) advertising – we use cookies to help us to display advertisements that will be relevant to you
(g) analysis – we use cookies [to help us to analyse the use and performance of our website and services
(h) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally

14.

Cookies used by our service providers

14.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

14.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

15.

Managing cookies

15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

15.2 Blocking all cookies will have a negative impact upon the usability of many websites.

15.3 If you block cookies, you will not be able to use all the features on our website.

16.

Cookie preferences

16.1 You can manage your preferences relating to the use of cookies on our website by actioning the information on cookies above.

17.

Our details

17.1 This website is owned and operated by Mandeep Johal of Who Do You Think I Am?.

17.2 We are registered in England and Wales under company number 9055047, and our registered office is at Sovereign House, 184 Nottingham Road, New Basford, Nottingham Ng7 7BA

17.3 Our principal place of business is at Sovereign House, 184 Nottingham Road, New Basford, Nottingham Ng7 7BA

17.4 You can contact us:
(a) by post, to [the postal address given above;
(b) using our website contact form;
(c) by email, using the email address info@whodoyouthinkiam.org

18.

Data protection registration

18.1 We are exempted to be registered as a data controller with the UK Information Commissioner’s Office.