This Privacy Notice tells you what to expect in relation to personal information about you which is collected, handled and processed by MILSPO NETWORK CIC trading as “Find a Milspo”, hereafter referred to as “MILSPO™ ”.
We acknowledge and agree that any personal data of yours that we handle will be processed in accordance with all applicable data protection laws, the General Data Protection Regulations (“GDPR”) and the Privacy And Electronic Communications Regulations (“PECR”)
WHO ARE WE?
MILSPO™ is a global network that supports all UK military spouses, partners and other-halves who are building the businesses of their dreams. MILSPO™ operates as a Community Interest Company.
With regards to all data handled by MILSPO™ we act as both Data Controller and Data Processor.
“Find a MILSPO” is a directory where military spouses, partners, other-halves and veterans can upload details of their business to allow others to find and connect with them.
HOW WE COLLECT DATA FROM YOU
Data may be collected on our website in the form of cookies or by use of the contact us forms. Data is also collected by MILSPO™ verbally and by written communications such as emails, SMS and software based communications.
Directory information is uploaded directly by the data subject; in doing so they are giving MILSPO™ permission to hold and advertise this information on their behalf. As data is uploaded by the user, MILSPO™ cannot be held liable for any mistakes nor the consequences of these.
All data subjects will have an amendable profile where they can rectify mistakes, update information and best represent their business.
THE INFORMATION WE MAY COLLECT
In addition to data directly uploaded by the data subject, MILSPO™ may collect the information which is necessary for us to be able to provide you with our best services; we will never ask for nor store any additional details which are not relevant.
The personal data about you that we may collect, hold and process includes but is not limited to:
- Contact details
- Payment Details
- Cookies for analytics and website optimisation
SPECIAL CATEGORY DATA
MILSPO™ will not process any Special Category Data; this includes but it not limited to; race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation. Our services are aimed at people of legal age and we do not intentionally collect personal data from those under the age of 19 without the consent of a parent or guardian. We advise that any information you provide us that falls within this category is removed from all written communication and request that Special Category Data is not uploaded in your directory profile.
HOW WE HOLD YOUR DATA
All the data we hold is stored as securely as possible; where third party cloud storage is used we are reliant on the security systems in place and cannot be held responsible for a breach on their part. MILSPO™ follows all guidelines set in place around password protection.
DISCLOSURE OF YOUR INFORMATION
We will not pass on personal data to a third party unless;
- Required to for legal circumstances
- Required to for the purposes of completing a task set to us by you – in this circumstance your full awareness and consent will be required
Personal data shall not be transferred to a country or territory outside the EEA unless that country or territory ensures an adequate level of protection or the appropriate safeguards are in place for your rights and freedoms. In case of transfer of personal information from EU/EEA to third party outside the EEA, we will be entering into EU Standard Contractual Clauses with that third party. Further details of EU Standard Contractual Clauses can be found here
Other trusted third parties that we may share your data with are as follows: HM Revenue and Customs, legal advisors and other companies for the purpose of engaging in business with you.
RIGHT TO BE INFORMED
MILSPO™ will make a sustained effort to inform you of the data we hold on your behalf; our methods will include verbal notification when we speak with you on the telephone and written notification which will include explicit email correspondence and this Privacy Statement which we will publish on our website.
RIGHT TO OBJECT TO DIRECT MARKETING
You have the right to object to, and therefore be removed from, direct marketing from MILSPO™. MILSPO™ may on occasion send you information about offers, tips or business updates.
MILSPO™ also uses the PECR guidelines in conjunction with GDPR with regards to marketing.
To sign up for our email notifications you must first opt in; if you no longer wish to receive this information you must notify us in writing as described in the “Concerns” section.
RIGHT TO OBJECT TO PROCESSING OF INFORMATION
You have the right to object to our processing of your data under Legitimate Interest; please raise this objection with us in writing. MILSPO™ has the right to refuse an objection on the following basis; where the information is held for contractual reasons, where the information is held pending legal action, or where the information held does not cause substantial damage or distress to the data subject.
If you chose to raise an objection in writing, we will consider the balance of interests and will report back to you on our decision within 30 working days. If you are not satisfied by our response you have the right to complain to our governing authority, the ICO.
RIGHT OF ACCESS
You have the right at any time to ask for a copy of the information about you that we hold. MILSPO™ will provide a report detailing this information within 1 month of the request, as per GDPR regulations.
If you would like to make a request for information, please email firstname.lastname@example.org.
RIGHT TO RECITIFICATION
If any of the data we hold on you is incorrect, please inform us via email@example.com and we will rectify this immediately. MILSPO™ will do everything within its power, and with proportionate effort, to ensure that data is accurate and up to date.
RIGHT TO ERASURE
Under GDPR individuals have the right to request their personal details are erased; this can be done verbally or in writing. MILSPO™ will respond to each request within 1 month of receiving it with the process we will take to ensure this right is upheld.
MILSPO™ has the right to refuse an objection on the following basis; where the information is held for contractual reasons, where the information is held pending legal action, or where the information held does not cause substantial damage or distress to the data subject.
For more information, please email firstname.lastname@example.org
RETENTION OF YOUR DATA
Your data will be retained for no longer than is necessary and in accordance with our Data Retention Policy. Our criteria for retention varies dependant on the information we hold and the relationship we have with you and rests upon the following; how long we have had an on-going relationship with you, if we have any legal obligations requiring your data, if retention is required to establish our legal position (e.g. statute of limitations, litigation etc)
If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in the first instance at email@example.com
We hold ourselves accountable to the Information Commissioners Office who can be contacted at https://ico.org.uk/concerns
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
LINKS TO OTHER WEBSITES
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
CHANGES TO THE PRIVACY NOTICE
This Privacy Notice may be changed by us at any time. We will notify you of changes: [e.g. by posting the change on our website and social media, sending you a message through a secure channel, or any other reasonable means.]