PRIVACY POLICY

Last updated: 28 February 2022

The Pinsker Centre (company number 12919984) (“us”, “our”, “we”, “Pinsker”) is the controller of your personal data. Pinsker is committed to protecting and respecting your privacy.

1. Introduction

This privacy policy (the “Privacy Policy”) sets out the types of personal data we collect when you access and visit https://www.pinskercentre.org/ (the “Website”) and how we may manage and use that data. It also applies to when we provide services to you via the Website or by telephone or in person, or where you otherwise engage with us,.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notices that we may provide when we are collecting or process personal data about you so that you are fully aware of how and why we are using that data.

This Privacy Policy supplements other terms, notices or policies and is not intended to override or replace them.

By visiting or otherwise using our Website, you accept that you have read and understood this Privacy Policy. If, for any reason, you do not agree with the content of this Privacy Policy, please stop using this Website.

We reserve the right to revise or amend this Privacy Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant, we will endeavour to let you know. However, it is your responsibility to check this Privacy Policy before each use of the Website.

Our Website and our services are not intended for children and we do not knowingly collect personal data relating to children.

2. What information do we collect?

The personal data we collect from you may include:

Identity Data: which includes your full name, date of birth and passport number.
Contact Data: which includes your billing address, delivery address and e-mail address and telephone number(s).
Financial Data: which includes bank account and payment card details.
Technical Data: which includes your IP address, operating system, browser type and browser version.
Usage Data: which includes information about how you use the Website and our products and services.
Special Category Data: which may include information about your health, religious beliefs, race or ethnicity, political opinions, trade union membership, sexual orientation and genetic or biometric data.

Where this Privacy Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address.

3. How is your personal information collected?

Information you give to us

When you use the Website to complete a form, apply to participate in any of our programmes or events, contact us by social media, telephone, email or by post, report a problem with the Website, or offer your information to us in any other way, we may collect, store and use the personal data that you disclose to us.

Where you are applying to participate in one of our international programmes you will be asked to provide certain Special Category Data in order to facilitate your booking and participation. We will not process your Special Category Data without your explicit consent, but if you choose not to provide your consent then you will not be able to participate in our international programmes.

It is important that the personal data we hold about you is accurate and current. If you want to update the information you have previously given to us, please contact us.

Automated technologies or interactions

Each time you use our Website we will automatically collect your personal data including Technical Data and Usage Data. We collect this data using technologies such as cookies or other similar tracking technologies.

We use this data for several different reasons. Firstly, we use it to ensure that the Website works properly and that you are able to receive the full benefit of it. Second, we use the data to monitor online traffic and audience participation across the Website. We undertake both of these activities because we have a legitimate interest in doing so.

Please refer to our Cookies Policy below for further details.

Third parties or publicly available sources

We may also receive personal data about you from various third parties, and public sources, such as: analytics providers, advertising networks and search information providers.

4. How and why we use your personal data?

Lawful basis for processing your information

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 you have asked us to do so, or consented to us doing so;
Where we need to do so in order to perform a contract we have entered into with you;
Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and
Where we need to comply with a legal or regulatory obligation.

Here are some examples about how we may use the information we collect about you and the lawful basis we rely on to do so:

Activity: To deliver the Website to you.

Examples of the types of personal data we may collect: Technical Data and Usage Data.

Lawful basis for processing: Performance of contract with you

Activity: To process and deliver your order of our products or services.

Examples of the types of personal data we may collect: Identity Data, Contact Data, Financial Data and Special Category Data.

Lawful basis for processing: Performance of contract with you. Consent (in the case of special category data).

Activity: To administer and protect our business and this Website (including troubleshooting, data analysis and system testing.)

Examples of the types of personal data we may collect: Identity Data, Contact Data and Technical Data.

Lawful basis for processing: Necessary for our legitimate interests (for running provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). Necessary to comply with a legal obligation.

Activity: To use data analytics to improve our website.

Examples of the types of personal data we may collect: Technical Data and Usage Data.

Lawful basis for processing: Necessary for our legitimate interests (to keep our website updated and relevant).

Marketing

We may use your personal data to contact you about our latest news, our products or our services (we call this marketing).

You will receive marketing communications from us if you have:

subscribed to receive marketing communications from us; or
signed up to our events, and you have not opted out of receiving marketing when you provided us with your email address.

To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email, or you can also contact us.

We will get your express opt-in consent before we transfer your personal data to any third party for its own marketing purposes.

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.

5. Sharing your personal data

Depending on how and why you provide us with your personal data we may share it in the following ways:

with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
with selected third parties who we sub-contract to provide various services and/or aspects of the Website’s functionality, such as where third-party plugins provide functionality such as message boards or image hosting services (see “Service Providers” below); and
with analytics and search engine providers that assist us in the improvement and optimisation of this Website as described above.

We may also disclose your personal data to third parties in the following events:

if we were to sell or buy any business or assets, in which case we might disclose your personal data to the prospective seller or buyer of such business or assets as part of that sale;
if Pinsker or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;
if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or
in order to enforce or apply our Website’s terms of use or terms and conditions; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where you participate in one of our international programmes we are required to share your personal data (including Special Category Data) with our overseas partners and international agencies. We will obtain your explicit consent to the transfer of Special Category Data to third parties at the time of booking.

Service Providers

Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. The following is a list of the type of trusted service providers we use:

Wix
Website Developers
Analytics Providers
Payment Processors
Client Relationship Management System Providers

Links to third party sites

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

6. For how long do we keep your personal data?

We will hold your personal information on our systems only for as long as required to provide you with the services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

7. Security

Pinsker takes the protection of your information very seriously. Where we have given you a password that enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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.

8. International Data Transfers

Some of our external third party providers and partners are based outside of the UK and their processing of your personal data will involve a transfer of data outside of the UK.

Whenever we transfer your personal data outside of the UK, at least one of the following will apply:

the transfer your personal data will be to countries that have been deemed to provide an adequate level of protection for personal data by the UK; or
we will enter into specific contracts approved for use by the UK ICO which give personal data the same protection it has in the UK; or
the transfer of your personal data will otherwise be permitted under one of the derogations available under the Data Protection Act 2018; or
you will have given us your explicit consent to the proposed transfer.

If you would like more information about how the mechanism via which your personal data is transferred, please contact us.

9. Your Rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data.

If you wish to exercise any of your rights set out below then please contact us. When you contact to us making a request to exercise your rights, we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity. 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 could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could 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.

Right of Access

You may, at any time, request access to the personal data we hold about you (you may have heard of this right being described as a "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.

Your Right to Rectification

You may request that we correct personal data that we hold about you which you believe is incorrect or inaccurate, though we may need to verify the accuracy of the new data you provide to us.

Your Right to Erasure

You may ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”). If for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.

Your Right to Object to Processing

You may object to processing of your personal data where we rely on legitimate interest for processing that personal data. You also have the right to object where we are processing your personal data for direct marketing purposes. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.

Your Right to Restrict Processing

This enables you to ask us to suspend the processing of your personal data in the following scenarios:

if you want us to establish the data's accuracy;
where our use of the data is unlawful, but you do not want us to erase it;
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
you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Your Right to Portability

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.

Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

Your right to withdraw consent at any time

You may withdraw your 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.

10. Contact Details

If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us by emailing at info@pinskercentre.org .

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

COOKIES POLICY

Last updated: 8 October 2019

INFORMATION ABOUT OUR USE OF COOKIES

1. We use cookies to distinguish you from other users of our Website. This helps us improve our Website and provides you with a better experience.

2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device's hard drive.

3. Cookies can be stored for varying lengths of time on your browser or device. Session cookies are deleted from your device when you close your web browser. Persistent cookies will remain stored on your device until deleted or until they reach their expiry date.

4. We use the following cookies:

Strictly necessary cookies: These are cookies that are required for the operation of our Website. This includes, for example, cookies that enable you to log into secure areas of our Website. Because these cookies are strictly necessary, we do not need to ask for your consent to use them.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around Website when they are using them.

Functionality cookies. These are used to recognise you when you return to use our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region, or information you have already completed on a loan application form).

Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our advertising more relevant to your interests. We may also share this information with third parties for this purpose.

5. You can find more information about the individual cookies we use and the purposes for which we use them as set out below:

Essential Cookies

These cookies will be automatically deployed onto your computer when you use the Website.

Cookie Name: bsession

Purpose of Cookie and Information Collected: Registers which server-cluster is serving the visitor. This is used in context with load balancing, in order to optimize user experience.

Cookie Duration: 1 day

Cookie Name: Hs

Purpose of Cookie and Information Collected: Ensures visitor browsing-security by preventing cross-site request forgery. This cookie is essential for the security of the website and visitor.

Cookie Duration: Session

Cookie Name: JESSIONID

Purpose of Cookie and Information Collected: Preserves users states across page requests.

Cookie Duration: Session

Cookie Name: ssr-caching

Purpose of Cookie and Information Collected: This cookie is necessary for the cache function. A cache is used by the website to optimize the response time between the visitor and the website. The cache is usually stored on the visitor’s browser.

Cookie Duration: 1 day

Cookie Name: unique_id

Purpose of Cookie and Information Collected: Preserves users states across page requests.

Cookie Duration: Session

Cookie Name: wix_premium_user

Purpose of Cookie and Information Collected: Registers whether the user is logged in. This allows the website owner to make parts of the website inaccessible, based on the user's log-in status

Cookie Duration: Session

Cookie Name: wixSessionTS

Purpose of Cookie and Information Collected: Contains a specific ID for the current session. This is necessary for running the website correctly.

Cookie Duration: Persistent

Cookie Name: XSRF-TOKEN

Purpose of Cookie and Information Collected: Ensures visitor browsing-security by preventing cross-site request forgery. This cookie is essential for the security of the website and visitor.

Cookie Duration: Session

Non-Essential Cookies

These cookies will be offered to you when you use our Website – you may accept or decline them depending on whether you are happy for them to be deployed onto your device or not.

Cookie Name: ahoy_visit

Purpose of Cookie and Information Collected: Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator.

Cookie Duration: 1 day

Cookie Name: ahoy_visitor

Purpose of Cookie and Information Collected: Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator.

Cookie Duration: 2 years

Cookie Name: fedops.logger.sessionId

Purpose of Cookie and Information Collected: Registers statistical data on users' behaviour on the website. Used for internal analytics by the website operator.

Cookie Duration: Persistent

Cookie Name: src

Purpose of Cookie and Information Collected: Detects how the user reached the website by registering their last URL-address.

Cookie Duration: 30 days

Cookie Name: POWR_PRODUCTION

Purpose of Cookie and Information Collected: Used in context with pop-up advertisement-content on the website. The cookie determines which ads the visitor should be shown, as well as ensuring that the same ads does not get shown more than intended.

Cookie Duration: Session

Cookie Name: svSession

Purpose of Cookie and Information Collected: Tracks a visitor across all wix.com sites. The information collected can be used to make advertisement more relevant for the visitor.

Cookie Duration: 2 years

Unclassified Cookies

Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.

Cookie Name: video