Privacy Policy

1. INTRODUCTION

1.1 Important information and who we are

13th Wimbledon Scout Group is part of the world wide scouting organisation.

We are committed to ensuring that the confidentiality and security of your information is protected. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

The Site is owned and operated by 13th Wimbledon Scout Group (“us”, “our”, “we”). We are committed to protecting the privacy of users of the Site.

At 13th Wimbledon Scout Group we are committed to protecting and respecting your privacy and personal data in compliance with the law and guidelines of the EU General Data Protection Regulation (“GDPR”)

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include customers and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

Please use the Glossary at the bottom of this policy to understand the meaning of some of the terms used in this Privacy Policy.

1.2 Who is Your Data Controller and Data Protection Officer

13th Wimbledon Scout Group is your Data Controller and is responsible for your Personal Data.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights surrounding your Personal Data please contact the DPO using the details set out below:

Email address: dpo@13thwimbledon.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3 Processing Data on behalf of a Controller and Processors’ responsibility to you

In discharging the responsibilities of the Data Controller, we have Processors who deal with your data on behalf of the Data Controller. Therefore, the responsibilities described below may be assigned to an individual or maybe taken to apply to the organisation as a whole. The Data Processor has the following responsibilities:

Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases).
Ensure that persons authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality
Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data
Obtain the prior specific or general written authorisation of the Controller before engaging another Processor
Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights
Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller
Maintain a record of all categories of processing activities carried out on behalf of a Controller
Cooperate, on request, with the supervisory authority in the performance of its tasks
Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process them except on instructions from the Controller
Notify the Controller without undue delay after becoming aware of a Personal Data Breach
Designate a data protection officer where required by the GDPR, publish their details and communicate them to the supervisory authority
Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations, and to maintain his or her expert knowledge

2. LEGAL BASIS FOR DATA COLLECTION

2.1 Types of Data / Privacy Policy Scope

Personal Data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

Profile/Identity Data: This is data relating to your first name, last name, date of birth.
Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
Communications Data: This is your preferences in receiving marketing information and other information from us.
Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
Customer Support Data: This includes feedback and survey responses.
Usage Data: information about how you use our website, products and services.
Personal Financial Data: This includes annual salary and current savings

We also collect, use and share Aggregated Data such as “30% of our customers are currently saving £x.” Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. 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 Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, 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.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow the collection and processing of Personal Data. The main avenues we rely on are:

Consent: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt-in’ to a service.
‍Contractual Obligations: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
Legal Compliance: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
Legitimate Interest: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address so that we know where to deliver something to, or your name so that we have a record of who to contact moving forward.

3. HOW WE USE YOUR PERSONAL DATA

3.1 Our Uses

We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact our Data Protection Officer.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
User signing up to the platform and creating an account	(a) Identity (b) Contact(c) Technical(d) Profile(e) Usage(f) Marketing and Communications	(a) Consent You will need to include Personal Data when filling in the calculators on the platform so the content you create is linked to your profile (b) Contractual Obligation In order to use our Platform, you need to contract with us under our Terms of Service and so this data is necessary to form the contract between us (c) Legitimate Interest We need to understand where you are logging in from so we know whether you can take advantage of our services, and what browser you are using so we can understand our customer demographic to help diagnose service provision issues, to keep our records up-to-date and analyse how customers use our services
User using the platform and has not created an account	(a) Identity(b) Contact(c) Technical(d) Profile(e) Usage(f) Marketing and communications	(a) Consent You will need to include Personal Data when filling in the calculators on the platform so the content you create is linked to your profile (b) Contractual Obligation In order to use our Platform, you need to contract with us under our Terms of Service and so this data is necessary to form the contract between us (c) Legitimate Interest We need to understand where you are logging in from so we know whether you can take advantage of our services, and what browser you are using so we can understand our customer demographic to help diagnose service provision issues, to keep our records up-to-date and analyse how customers use our services
Sharing Personal Information with third parties and of third parties (home buying partners)	(a) Identity(b) Contact	(a) Legitimate Interest The user has inputted certain Personal Data about connected third parties and circulated that Personal Data to other connected third parties because those third parties have indicated that they wish to participate in buying a home together. The User will have obtained consent from the third parties prior to entering the data into the Platform
To administer and protect our business (the Site and Platform) including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data	(a) Identity (b) Contact (c) Technical	(a) Legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (b) Contractual Obligation To be able to comply with all legal obligations surrounding data collection, processing and retention.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	(a) Legitimate interest To define types of customers for our products and services, to keep our Site and Platform updated and relevant, to develop our business and to inform users about marketing strategy

3.2 Marketing and Content Updates

You will receive marketing and new content communications from us unless you specifically request that you would not like to receive these communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 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 our Data Protection Officer.

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.

4. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 What Control Do I Have Over 13th Wimbledon Use Of My Personal Data?

We do not require you to make an account on the platform but we do create a ‘shadow’ account where we store your Personal Data in response to questions we ask of you. There is a button on the platform which can allow you to delete this shadow account and this will delete all of the Personal Data we have stored about you. For more information please contact our Data Protection Officer.

4.2 How Does 13th Wimbledon Protect Customer Data?

We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including encryption and bank-level security. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of 13th Wimbledon to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.

4.3 Opting Out Of Marketing Promotions

You can ask us to stop sending you marketing messages at any time by clicking the “unsubscribe” button found within one of our marketing emails OR by contacting us at any time

Where you opt-out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.

4.4 How to Request your Data and the Process for Obtaining it

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure you have the 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.

5. YOUR DATA AND THIRD PARTIES

We may share non-personal data with third parties. We may share your Personal Data with subcontractors (only when necessary and with your consent) or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).

We may also share Personal Data with interested parties in the event that 13th Wimbledon anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.

If 13th Wimbledon is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations, your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

We may share your Personal Data at any time if required for legal reasons or in order to enforce our Terms of Use for our Site/Terms of Subscription or this Privacy Policy.

5.2 Third-Party Links

This Site 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 Site, we encourage you to read the privacy policy of every website you visit.

6. HOW LONG WILL WE RETAIN YOUR DATA FOR?

Home Buying Buddy site account – After 2 years inactivity, defined by the last login date.

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

7. AGE LIMIT FOR OUR USERS

This website is suitable for people of all ages

8. INTERNATIONAL TRANSFER OF DATA

We currently store all personal data within the UK. If we need to transfer and process your personal data in countries other than the UK, such as the EU countries or the United States we will put in place safeguards to ensure that your personal data remains protected.

If your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data (like New Zealand), or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).

9. NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 19th Dec 2023. By using 13th Wimbledon, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of 13th Wimbledon shall constitute your express acceptance of any modifications to this Privacy Policy.

10. INTERPRETATION

All uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious another way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).

Our staff are not authorised to contract on behalf of 13th Wimbledon, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a 13th Wimbledon address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any 13th Wimbledon rights, the email content shall be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the 13th Wimbledon legal department.

11. TERMS OF USE

Please also see our Terms of Use which set out the terms, disclaimers, and limitations of liability governing your use of 13th Wimbledon.

12. Glossary

GDPR: The General Data Protection Regulation (EU) 2016/679 (GDPR)
Users: Any individual who either browses the public website, engages with our chat support feature, speaks with our employees and staff members, creates a profile or uses our Platform as a signed-up user.
Personal Data: Information relating to an individual who can be directly identified from the information. Personal Data includes factual information as well as expressions of opinion or intentions.
Data Controller / Controller: The organisation that determines the manner and purposes for which Personal Data is to be processed. In our case, SeedLegals Limited.
DPO: The Data Protection Officer, currently Paul Carse
Personal Data Breach: Loss, theft or unauthorised access, use or disclosure of Personal Data.
Privacy Policy: Our Privacy and Data Protection Policy
Aggregated Data: Statistical or demographic data derived from your personal data but not considered personal data in law as the data will not directly or indirectly reveal your identity.
Processors: Volunteers of 13th Wimbledon are authorised to discharge the responsibilities of the Data Controller.

If you have any other questions about the interpretation of this Privacy Policy please get in contact with our DPO using the contact information above.

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