The School of Strut is committed to ensuring your privacy and that your data is secure at all times. In order to process your membership, shop purchases and other website use, we need to collect a minimum of information which is collected in accordance with the UK Data Protection Act 1999. Your data is shared with third party service providers only when necessary to provide a requested service (e.g. email newsletters or processing your membership payments), and will not be sold or shared for any other purpose.
This privacy notice is to give you inform on how School of Strut collects and processes your personal data through your use of this website, including any data provided when you sign up for a newsletter, purchase a memerbship or product, or take part in any competitions.
Who We Are:
Our website address is https://www.schoolofstrut.com
This website may include links to third-party websites, plug-ins and applications. 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 statements. When you leave our website or decide to share you data with a third party, we encourage you to read the privacy notice of every website you visit.
The Data We Collect About You and Why We Collect It:
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, middle name(s), last name, and username or similar identifier. This is to provide you with marketing/membership services.
- Contact Data includes billing address, delivery address, email address and telephone numbers. This is to provide you with marketing/membership services or product orders.
- Financial Data includes bank account and payment card details. This is to provide you with marketing/membership services or product orders.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. This is to provide you with marketing/membership services or product orders.
- Technical Data includes internet protocol (IP) address, your login data, 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. This is to enable us to provide membership services and understand how you use the website to supply a better experience.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. This is to provide you with marketing/membership services or product orders.
- Usage Data includes information about how you use our website, products and services. This is to enable us to provide membership services and understand how you use the website to supply a better experience
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic 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 or visiting a specific website page. 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 collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, 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.
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.
How is Your Personal Data Collected?
Direct interactions – You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you sign up for our newsletters, memberships, work together in any capacity or give us feedback.
Third parties or publicly available sources – We may receive personal data about you from various third parties and public sources.
Technical Data from the following parties:
- Analytics providers such as Google, based outside the EU
- Social Media Networks such as Facebook, Twitter and Instagram. Based outside the EU
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal, and Stripe based outside the EU;
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.
You can find out more about the types of lawful basis that we will rely on to process your personal data here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/lawful-basis-for-processing/
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data:
- To register you as a new customer
- To process and deliver your order including managing your memberships, payments, fees and charges, and collecting money owed to use for those services
- To deliver relevant website content to you
- To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
- To make suggestions and recommendations to you about goods or services that may be of interest to you
- To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
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 (we call this marketing).
You may receive marketing communications from us, or from us but on behalf of our clients, if you have requested information from us or purchased goods or services in the past from us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the School of Strut for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us.
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 or other transactions.
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.
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 employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- 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.
If you wish to exercise any of the rights set out above, please contact the DPM.
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 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 updated.
Who we share your data with:
The School of Strut is required to share some data with third party providers in order to supply our website and services effectively, and to enable your memberships and other functionality. They currently include:
- Google Analytics: Anonymous user data for us to understand how the website is being used and make improvements.
- Mailchimp: To provide our newsletters and other email services
- Paypal: To provide payment services for products, memberships and other paid functionality on the School of Strut
- Stripe: To provide payment services for products, memberships and other paid functionality on the School of Strut
Access To Your Information:
Access to the infromation provided to the School of Strut is limited to employees of the School of Strut, including the Administrators of the School of Strut website and limited third party sub-contractors employed specifically for the purpose of maintaining the School of Strut website and functionality, who are contractually bound to only use such information for the express purpose of maintaing the functionality of the website and for no other purpose..