Privacy Policy

Privacy Policy

The following statement explains our policy regarding the personal information we collect about you.

REFRESH is committed to being transparent about how it collects and uses your data and to meeting its data protection obligations. This Privacy Policy is to help you understand what data we collect and what we do with it. This is important, we hope you will take time to read it carefully. If you have any questions about the policy, they can be directed to data.protection@wrap.org.uk.

From time to time, you will be asked to provide personal information about yourself (eg name and email address etc) in order to receive or use services on our website. In addition we automatically collect certain data which we outline below. Some of this information is stored in cookies, you can find out how we use these in our cookies policy.

How we process your data

We process your personal data in these ways:

For certain legitimate interests:

  • to improve your experience
    • to allow you to sign in and stay signed in on our site
    • to display content suitable to your device
  • to measure the effectiveness of our website and marketing channels;
  • to determine the effectiveness of resources
    • g. to provide a follow up email after a user has download a specific resource to understand the business change that may have happened.
  • to identify and prevent fraud
  • to identify and prevent spam; and
  • if you are one of our members, to send you email marketing communications.

Based on your consent:

  • to provide you with a personalised experience
    • e. providing content tailored to you
  • to send you marketing communications
    • e. email marketing and online advertising, for which we will gain separate consent
  • to measure the effectiveness of our audience profiles on our website and marketing channels
  • for research purposes.

and to comply with a legal obligation.

What data we collect

The data we collect includes:

  • Name, email address, postcode, country and telephone number
  • Organisation and job title
  • IP address
  • Website actions (i.e. content viewed and downloaded)
  • Marketing preferences
  • Audience profiling
  • Information specific to an event i.e. dietary needs. The information will only be used for the event.

Sharing your data

Subject to applicable data protection law, we may share your personal data with:

  • Companies who provide services to us
  • Legal and professional advisors or bodies
  • Fraud prevention companies
  • An organisation we sell or license the relevant part of the business in order to retain your legitimate interests.
  • Any other organisation where we have gained your consent or where it required by law.

Whenever we process data for these purposes we will ensure that we always keep your Personal Data rights in high regard and take account of these rights. You have the right to object to this processing if you wish, and if you wish to do so please contact us.

How long we keep your data

  • Website accounts
    • Where we can’t identify when someone last signed in we will retain the information for the lifetime of the application in order to retain your legitimate interests in using the application.

 

  • Web application accounts
    • Where we can identify when someone last signed in we remove accounts that have been inactive for 4 years
    • Where we can’t identify when someone last signed in we will retain the information for the lifetime of the application in order to retain your legitimate interests in using the application.

 

  • Google Analytics
    • User-level and event-level data stored by Google Analytics is automatically deleted from Analytics’ servers after 50 months.

 

  • Email marketing lists
    • You have the option to unsubscribe from one of our email marketing lists, and we will always honour this. We will also periodically clean our lists to ensure they are up-to-date.

 

 

Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

  • Right of access – you have the right to request a copy of the information that we hold about you.
  • Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
  • Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation.
  • Right to object – you have the right to object to certain types of processing such as direct marketing.
  • Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

Access to your personal information

In line with the above rights, you have the right to request a copy of the personal information REFRESH holds about you, to have any inaccuracies corrected, or request that it be deleted. Please address requests to the person responsible for Data Protection (email: data.protection@wrap.org.uk).

Users under 18

If you are under 18, please get your parent/guardian’s permission beforehand whenever you provide personal information to REFRESH. Users without this consent are not allowed to provide us with personal information.

Contact Us

If you have any questions about this Privacy Policy or you wish to make a complaint about how your personal data is being processed by us, or how your complaint has been handled, you have the right to lodge a complaint directly with the Supervisory Authority and REFRESH’s data protection representative.

The details for the latter are:

Data Protection data.protection@wrap.org.uk

WRAP
2nd Floor Blenheim Court
19 George Street
Banbury
OX16 5BH