Effective Date: 5 November 2021
Purposely’s goal is to support founders to embed purpose into their business by using or considering the company limited by shares legal structure. As such, we provide a website application that you can use to create your company articles, and embed purpose into the DNA of your business.
- What is Personal Data?
- The Data Controller
- The information we collect and how we use it
- 4. Lawful Bases
- Sharing your personal data with our partners and third parties
- Third party websites
- International data transfers
- Security of your information
- How long we store your personal data for
- Contact us
1. What is Personal Data?
- Under the UK General Data Protection Regulation (Regulation (EU) 2016/679) and Data Protection Act 2018 (together the “Data Protection Law”), personal data is defined as ‘any information relating to an identified or identifiable natural person (the 'data subject’), by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person'.
2. The Data Controller
- A data controller is the individual or legal person who controls and is responsible to keep and use personal data in paper or electronic files. UnLtd is the data controller of personal data collected by the Purposely tool, as defined by Data Protection Law.
3. The information we collect and how we use it
- We may process your personal data for various reasons, including:
- If you sign up to Purposely, we collect your name and email address in order to enable you to log into and use the platform for the benefit of your business.
- If you visit our website, by using this website and agreeing to these terms and conditions.
- If you contact us by phone, email or in writing:
- If you exchange emails, telephone conversations or other electronic communications with our staff members, our systems will record details of those conversations, sometimes including their content.
- When you contact us, we sometimes need to keep a record of the communication we have with you to operate, manage and develop our organisation.
- As otherwise disclosed at the time of collection or use.
- We do not use automatic decision-making or engage in profiling. If a situation arises where we intend to use your personal data for any reason beyond and incompatible with its original purpose, we will notify you and provide additional information ahead of time.
4. Lawful Bases
You are under no statutory or contractual obligation to provide us with your personal data. If you choose not to do so, of course, we may not be able to contact you. Lawful Bases
- We will only use personal data when the law allows us to (i.e. where we have a ‘lawful basis’). At least one of these must apply whenever personal data is to be processed:
- Consent: you have given Purposely your free, specific, informed or unambiguous consent for your personal data to be processed for a specific purpose (for example, we may ask for your consent to send you marketing).
- Contract performance: the processing is necessary for the performance of a contract you have with Purposely, or in order for Purposely to take steps at your request prior to entering into a contract.
- Compliance with legal obligation: the processing is necessary for Purposely to comply with the law for tax, social security obligation and employment purposes (not including contractual obligations).
- Protection of vital interests: for example, where the processing is vital to an individual's survival.
- Legitimate interests: the processing is necessary for Purposely's legitimate interests, or the legitimate interests of a third-party (for example, in order to administer your sign-up on the website), unless there is a good reason to protect the individual's personal data that overrides those legitimate interests.
5. Individual Rights
- Your data subject rights are listed below:
- To request access to the personal data we hold about you;
- To request that we rectify or erase your personal data;
- To request that we restrict or block the processing of your personal data;
- To object to our processing of your personal data in certain circumstances;
- Under certain circumstances, to ask us to port personal data about you that you have provided to us to you or a third party; and
- Where we previously obtained your consent (or are relying on consent to process your personal data), to withdraw consent to processing your personal data.
- Under Data Protection Law, you may ask for a copy of the information we hold about you and you may request rectifications be made to this information if it is inaccurate or not up to date. Please email DPO@unltd.org.uk to exercise any of your rights.
6. Sharing your personal data with our partners and third parties
- We may disclose your personal data to our sponsoring partners (for example, Bates Wells LLP) or third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any agreements, or to protect the rights, property, or safety of the organisation, or other individuals.
- This includes exchanging information with other companies and organisations for the purposes of safeguarding or other statutory regulations we have to comply with as well as those organisations with whom you and we have reciprocal agreements for providing services for education or professional development.
- Bates Wells LLP is a limited liability partnership registered in England and Wales (OC325522), For further details about how they process personal data, please see their privacy notice here.
7. Third party websites
- Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
8. International data transfers
- The data that we collect from you will be processed at our servers in the UK.
- If personal data is transferred outside the UK to a country without a designated ‘adequacy’ rating from the Secretary of State, Purposely will request the data subject's consent before processing the data. Consent will not be sought where the processor's Binding Corporate Rules, Standard Contractual Clauses or adhoc contractual clauses stipulate that the data will be processed in accordance with Data Protection Law.
9. Security of your information
- To help protect the privacy of data and personal data you transmit through use of this our website, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.
10. How long we store your personal data for
- We store your personal data in accordance with our data retention policy. This policy is reviewed and updated internally to ensure we do not store your data for longer than is necessary. We also review how and where we store any data to ensure that we meet our obligation to store data securely.
- In addition, some of the data we hold may be subject to certain legal and regulatory obligations, which provide a minimum retention period for different types of data. The retention period varies depending on the data we hold.
- The criteria used to determine the period of storage of personal data is:
- The respective statutory retention period;
- Our contractual and/or business relationships with you;
- Potential disputes; and
- Any guidelines issued by relevant supervisory authorities.
- After expiration of that period, the corresponding information is routinely securely deleted, as long as it is no longer necessary for the fulfilment of a contract, the initiation of a contract or to protect or defend our position or that of a third party. If you have any questions about retention periods, please contact DPO@unltd.org.uk
- For further information on your rights and how to complain to the ICO, please refer to the ICO website at ico.org.uk/concerns.
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UnLtd Head Office 123 Whitecross Street, Islington, London, EC1Y 8JJ.