At Shadow Heroes, we respect your privacy and are committed to protecting your personal data. This notice explains how we use personal data and cookies:
To understand how we may use your information and cookies, it is important that you read this notice – along with any other privacy notices we may provide on specific occasions when collecting personal information about you.
By continuing to use the site, or by providing us with your personal information (through the site, via the programme or otherwise), you acknowledge our use of your personal information and cookies, as described below.
This section explains how we collect, process and look after any personal information that we collect about you.
OUR STATUS AS A DATA CONTROLLER
We are responsible for protecting personal information that we collect about you, and we act as a data controller when we use such information. Your “personal information” or “personal data” means any information about you from which you can be identified.
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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
The site, and our other communications with you, may contain links to other online or mobile sites. We are not responsible and accept no liability for the privacy practices or content of such sites.
We may collect personal information about you in connection with the site or our programme in the following circumstances:
We seek to keep your personal information correct and up-to-date. Please let us know if you believe that any information we hold about you should be corrected or updated.
However we use your personal data, we make sure that our use complies with lawful bases for using or otherwise processing your personal data. We may rely on one or more of those bases when we process your personal data, and we explain those below.
INFORMATION WE COLLECT ABOUT YOU THROUGH THE SITE OR WHEN YOU CONTACT US BY OTHER MEANS
We may use such information for the following purposes and reasons:
INFORMATION WE COLLECT ABOUT YOU IN CONNECTION WITH OUR PROGRAMME
Whether you deal with us via the site or our programme, please do not provide us with any personal information if you do not want that information to be used by us in the ways noted above.
INFORMATION FROM OTHER SOURCES
We may collect information about you through channels other than the site, a contract or form – for example, if you obtained our contact details from another source, if you met our staff in person, or if your details were provided to us by a third party (e.g. your school) who gave us your information in the context of our delivering our programme. If so, we will treat your personal information in accordance with this policy.
We do not generally seek to collect any “special categories” of personal data about you: that would include 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 seek to collect any information about criminal convictions and offences. We may collect aggregated data about race or ethnicity for the purposes of evaluating our programme, but in an anonymised manner.
To the extent that you provide us with any special categories of personal data about you (or any details of criminal convictions or offences), then we process that information with your explicit consent, which you give to us by providing that information to us, for (a) the purpose for which you have voluntarily provided such information and (b) any purpose that is reasonably compatible with such purpose. You may withdraw that consent at any time by contacting us. Please note that we might have other legal grounds for processing such special data, such as if those data have been manifestly made public by you, but we will not process such data without such a lawful reason.
The site is not intended for children under the age of 13, and we do not knowingly collect any personal data relating to any children under the age of 13 – unless in the course of an extension of our programme, in which case we may make special arrangements to do so by providing a specific privacy notice and we shall, where required, seek consent for processing from the child’s parent or legal guardian.
IF YOU FAIL TO PROVIDE DATA
Where we need to collect personal data by law, or under the terms of a contract that we have with you and you fail to provide that data when requested, we may not be able to perform the contract that we have or are trying to enter into with you. If so, we shall notify you if that is the case at the time.
CHANGE OF PURPOSE
We shall only use your personal data for the purposes for which we collected the data, unless we reasonably consider that we need to use such data for another reason and that reason is compatible with the original purpose. If you would like to get an explanation of 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 shall notify you and we will explain the legal basis on which we intend to rely.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, if and to the extent that this is required or permitted by law.
We may disclose your personal information collected via the site or in connection with our programme to certain third parties, but only in the following limited circumstances:
We may transfer your personal information outside the European Economic Area (EEA) where the transfer is necessary for (a) the performance of our contract with you (or for implementing pre-contractual measures taken at your request) or (b) the conclusion or performance of a contract concluded in your interest between us and a third party or (c) another lawful condition (such as the establishment, exercise or defence of legal claims).
We do not otherwise typically transfer your personal information to locations outside the EEA. To the extent that we do so, we will strive to ensure that a similar degree of protection is afforded to such information by ensuring that at least one of the following safeguards is implemented:
For further details of such safeguards, please see the European Commission’s website. Please contact us if you would like further information on any specific mechanism used by us when transferring your personal information outside the EEA.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties that have an operational need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected such information (or for any compatible purpose), including for the purposes of satisfying any legal, accounting or reporting requirements. In some circumstances you can ask us to delete your personal information: please see section 8 below.
If you have applied for work with us, then we will retain your personal information for the duration of the period in which we are considering your application. If you are successful in your application, then we will continue to retain your personal information for the duration of your employment or engagement, and following the end of your employment or engagement, in accordance with our document retention policy for former staff. If your application is not successful, or we do not have a suitable position available at that time, we will retain your personal information for up to 12 months and, with your permission, for longer so that we can let you know about other appropriate opportunities that may arise in the future (but you may contact us at any time to request that we delete your application and any personal information we are holding about you).
Under certain circumstances, you have the following rights under data protection laws in relation to your personal information:
To find out more about these rights, please visit the ICO’s website.
If you wish to exercise any of those rights, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in those circumstances.
We may need to request specific information from you to help us confirm your identity and to 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 are not disclosed to any person that has no right to receive such data. We may also contact you to ask you for further information in relation to your request to speed up our response.
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 shall notify you and keep you updated.
This section explains how we use web analytics to help us monitor how the site is being used so that we may improve its functionality and accessibility to users.
Cookies are widely used to allow websites to function efficiently. A cookie is a small file of letters and numbers that (depending on your browser settings) is deposited on your browser or the hard drive of your computer, mobile phone or other smart device (each, a “device”) when you visit an online or mobile site, if you agree. Cookies contain information that is transferred to your device’s hard drive. The cookie may be sent back to that site when you visit again, and may then be used by the server to identify and track your use of the site.
We do not currently use first-party cookies on the site.
Our own policy does not cover any third-party online or mobile sites that are linked to the site. If you click through to those sites, they may set cookies on your device. To understand which cookies are used by those third parties and how they use your data, please read their privacy and cookies policies. We accept no responsibility or liability for those third-party sites.
The site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics measures how users interact with our site content through the use of tracking cookies. As a user navigates between web pages, Google Analytics provides our site with tags to record information about the page a user has seen, such as the page URL, time and date of visit, length of visit, country of residence and language settings.
If you have any queries about this notice, including any requests to exercise your legal rights in relation to your personal data, then please contact us at:
Email address: firstname.lastname@example.org
We may at any time update or otherwise modify this notice. We will notify you of any changes to our notice by posting the modified notice on the site. This version was last modified on the date noted below.
Last modified: November 2020