Privacy Policy (Version 4)

Privacy Policy

This Privacy Policy is effective from the 25th May 2018 in line with General Data Protection Regulation guidelines.

Through ISO 9001:2015 accreditation, Aspire Active Education Group Ltd are committed to maintaining our highly regarded and respected quality service.

As part of our service, and in compliance with The Data Protection Act 2018 (EU GDPR) we are committed to protecting the privacy of our customers, users and stakeholders, ensuring that always you remain informed and in control of your information.

We are committed to protecting the privacy of all our customers and will always be transparent in how we manage data.

Our privacy policy will help you understand what information Aspire Active Education Group Ltd collects, how we use it and what choices you have.

About us:

The Aspire Active Education Group (AAE) comprises of the following organisations: Aspire Active Education Group (company number 10156357)

Aspire Active Camps Ltd (company number 06533710)

Aspire Active Education Ltd (company number 13499677)

Aspire Active Partnerships Ltd (company number 11785251)

Aspire Training Solutions Ltd (company number 08430411)

In addition to the organisations above you may come across terms “Aspire, “our”, “we”, “us”.

Our registered office is:

Unit 6, Holly Park Industrial Estate Spitfire Road

Erdington Birmingham B24 9PB

Our Data Protection Officer can be contacted directly here:

• james.trowman@aaeg.co.uk
• 0121 663 1979
  
  

This privacy notice explains:

• What personal information is
• The information we collect and how we collect it
• How we use your personal information

Personal information

Personal information is any information which identifies you or which can be identified as relating to you.

Any reference to “you” or “your” refers to you, or anyone whose personal information we process.

Our Commitment

As an essential part of our business, we collect and use customer data. In doing so, we observe relevant UK and Republic of Ireland data protection laws and respect customer’s privacy and rights.

We commit that we will:

•  Be completely open and honest about how we use your data.
•  Never share data with another organisation without your consent.
• Not send marketing communication to customers without lawful reason for doing so or unless they are happy for us to do so.
• Adopt the latest technological controls to ensure that the data which we hold electronically, is as secure as possible.
• Recognise rights and freedoms to which all our customers are entitled.

Processing your data using our Legitimate Interests.

We are only allowed to use your personal information if we have a legal basis to do so. We have several lawful reasons that we can use (or ‘process’) your personal data. This may be through our performance of a contract with you, we have consent or ‘legitimate interests’.

• Broadly speaking, legitimate interests mean that we can process your personal information if

The following are some examples of when and why we would use this approach during our normal course of business:

• To improve and enhance our services: When we do process your data, we will use it to benefit you and to make your experience better and to improve our products and services.
• Your best interest: Processing your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure.
• Personalisation: Where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our customers.
• Analytics: To process your personal data for the purposes of customer analysis, assessment, profiling and direct marketing, on a personalised or aggregated basis, to help us with our services and to provide you with the most relevant information if this does not harm any of your rights and
• Research: To determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you.
• Direct Marketing: We may send postal and email marketing. We will also make sure our postal and email marketing is relevant for you and tailored to your You also have the right to opt-out of receiving this information at any time by contacting us or updating your preferences.
• When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Who we share your personal information with?

In order to provide you with our services and meet our legal obligations, we only share your data with 3rd parties, in the following circumstances:

• To fulfil your order;
• To complete or confirm your location or postal address;
• To verify your identity and perform DBS checks;
• To authorise debit/credit card payments and any other transactions authorised by the supporter or customer;
• To manage and maintain the accuracy of your records;
• To handle complaints and improve customer service;
• To administer marketing on behalf of The Aspire Active Education Group (AAE)
• To meet legal obligations, for example, for the purposes of national security, taxation and criminal investigations; and
• If the Aspire Active Education Group (AAE) is acquired by a third party, in which case personal data held by it, about its customers, will be one of the transferred assets.

We’ll never make your personal data available to anyone outside The Aspire Active Education Group

(AAE) for them to use for their own marketing purposes without your prior consent.

Third-party links

Our 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 your data. 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 notice or policy of every website you visit.

Transferring your personal information outside the EEA

The EEA is the European Economic Area, which consists of the EU Members States, Iceland, Liechtenstein and Norway. We must tell you if we transfer your personal information outside the EEA.

We transfer your data outside of the EEA in very limited circumstances and have ensured that those organisations with whom we share your data look after it securely and have appropriate safeguards in place, as required by GDPR. These organisations are:

• “HubSpot” (2 Canal Park, Cambridge, MA 02141, USA) – provide our CRM system, customer communication system including email communication and survey platform. HubSpot relies on the European Commission's standard contractual clauses (or SCCs) as a valid data transfer mechanism between the EU and US.
• "Kajabi" (Kajabi LLC, 15495 Sand Canyon Ave #300, Irvine, CA, 92618, USA) - provide a business platform - Kajabi relies on the EU - U.S. DPF to transfer personal information that originated in the EEA to the U.S.
• “Facebook” (Facebook Inc, 1 Hacker Way, Menlo Park, CA 94025, USA) – Facebook provide a social media platform. – the transatlantic transfer of Facebook user data will be certified under the new Data Privacy Framework (DPF). and an appointed EU representative in Ireland (Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland)
• “Google” – (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Google provide an analytics service – Google relies on the EU - U.S. DPF to transfer personal information that originated in the EEA to the U.S.
• “LinkedIn” (LinkedIn Corporation, 1000 W.Maude Avenue, Sunnyvale, CA 94085, USA) – LinkedIn provide a social media platform. – LinkedIn provide the EU - U.S. DPF to transfer personal information that originated in the EEA to the U.S.
• “Microsoft Sharepoint” (1 Microsoft Way, Redmond, WA) – Microsoft relies on the European Commission's standard contractual clauses (or SCCs) as a valid data transfer mechanism between the EU and US.
• "theEducationCollective" (14 Connaught Avenue, Kidderminster, Worcestershire DY11 6LS) – Provide a portal and communication system for Aspire Active Partnerships.

Data Security

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 (including the ICO) of a breach where we are legally required to do so.

How long do we keep your personal information?

We will keep your personal information for as long as you are our customer or employee. Customer

After you stop being an active customer, because you have stopped regularly using our services or buying our products, we may keep your personal information for up to 6 years for one of the following reasons:

• To respond to any questions or complaints from you;
• To maintain our records;
• To comply with laws applicable to

After such time, we will securely delete your personal information. If we receive a bounce back from any of the emails that we send to you on several occasions, we will delete your personal information in relation to those emails.

Employee

For permanent employees, we keep personnel files for 6 years after an employment contract has ended. This information includes, but is not exclusive to employment contracts, training records and salary information. For temporary staff, we keep relevant records for 2 years.

This excludes members of the Senior Leadership Team, whose details are retained permanently.

Marketing

We may use your personal information to tell you about relevant services and any upcoming offers.

We can only use your personal information to send you marketing messages if we have either your consent or a legitimate interest to do so.

You can ask us to stop sending you marketing messages at any time – you just need to contact us or use the opt-out links on any marketing message sent to you. If you have setup an online account with us, then you can also change your communication preferences at any time.

Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of purchasing our services or any other transaction between you and us.

Your rights

Right to be informed

We will always be transparent in the way we use your personal data. You will be fully informed about the processing through relevant privacy notices.

Right to access

You have a right to request access to the personal data that we hold about you and this should be provided to you, under the General Data Protection Regulation (GDPR), within 30 days. If you would like to request a copy of your personal data, please contact us in writing.

Right to rectification

We want to make sure that the personal data we hold about you is accurate and up to date. If any of your details are incorrect, please let us know and we will amend them.

Right to erasure

You have the right to have your data ‘erased’ in the following situations:

• Where the personal data is no longer necessary in relation to the purpose for which it was originally collected or processed.
• When you withdraw
• When you object to the processing and there is no overriding legitimate interest for continuing the
• When the personal data was unlawfully
• When the personal data must be erased in order to comply with a legal

If you would like to request erasure of your personal data, please contact us in writing. Please note that each request will be reviewed on a case-by-case basis, and where we have a lawful reason to retain the data, it may not be erased.

Right to restrict processing

You have the right to restrict processing in certain situations, such as:

• Where you contest the accuracy of your personal data, we will restrict the processing until you have verified the accuracy of your personal data.
• Where you have objected to processing and we are considering whether The Aspire Active Education Group (AAE) legitimate grounds override your legitimate grounds.
• When processing is unlawful, and you oppose erasure and request restriction
• Where the Aspire Active Education Group (AAE) no longer need the personal data, but you require the data to establish, exercise or defend a legal claim.

Right to data portability

You have the right to data portability in certain situations. You have the right to obtain and reuse your personal data for your own purposes via a machine-readable format, such as a .CSV file. If you would like to request portability of your personal data, please contact us by writing to us this only applies:

• To personal data that you have provided to us;
• Where the processing is based on your consent or for the performance of a contract; and
• When processing is carried out by automated

Right to object

You have the right to object to The Aspire Active Education Group (AAE) processing your data in these circumstances:

• Where the processing is for direct Remember you can opt out of email communication at any time via the unsubscribe feature on our emails;
• Where the processing is based on legitimate interests;
• Where the processing is for purposes of scientific/historical research and

The Regulator

• If you feel that The Aspire Active Education Group (AAE) has not upheld your rights, we ask that you contact our Data Protection Officer whose details can be found in point 1 so that we can try and
• If you are not satisfied with our response, or believe we are not processing your data in accordance with the law you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). Their details are supplied below:

Information Commissioner’s Office

Wycliff House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113
Website: www.ico.org.uk

How to contact us

Aspire Active Education Group, Unit 6, Holly Park, Spitfire Road, Birmingham B24 9PB

Telephone 0121 663 1979

Email: info@aaeg.co.uk