PRIVACY POLICY

Friends Hearth - TMR Limited (company number: 9853917, registered in England & Wales) shall be referred to as “TMR”, “we”, “us”, “our” throughout this privacy policy. 

TMR respects your privacy and is committed to protecting your personal data in accordance with the EU General Data Protection Regulation (GDPR), and any country-specific data protection regulations applicable to Friends Hearth - TMR Limited.

This privacy notice will inform you as to how we look after your personal data, your privacy rights and how the law protects you when you visit our website www.tmrwembley.com (regardless of where you visit it from).

 

1. IMPORTANT INFORMATION

PURPOSE OF THIS PRIVACY POLICY

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you request us to contact you, or when you use our booking system.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.  This privacy notice supplements the other notices and is not intended to override them.

DATA CONTROLLER

TMR is the controller and responsible for your personal data collected through this website.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the manager using the details set out below.

CONTACT DETAILS

Name: Rahmat Simab

Email: info@tmrwembley.com

Address: Friends Hearth - TMR Limited, Rear Of, 203 Preston Road, Wembley, HA9 8NF, United Kingdom.

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 always contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version is dated 24th May 2018 and we reserve the right to amend this privacy policy in line with any legal requirements at any time.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications (such as social media platforms or links to our partners’ websites). 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 notice of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, 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 through this website and/or PayPal which we have grouped together follows:

  • Identity Data includes first name, last name, username or similar identifier and a brief description of your requirement and any other identity data that you provide through PayPal or the TMR website.

  • Contact Data includes address, e-mail address and telephone numbers and any other contact data you provide through PayPal and the TMR website

  • Profile Data includes personal description, qualifications, work experience, and customer feedback

  • Marketing & Communication Data includes products and services you have purchased, or expressed an interested in, business sector, exhibitions or events attended.

  • Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and/or PayPal.

  • Usage Data includes information about how you use our website and/or PayPal.

We also collect, use and share Aggregated Data such as statistical or demographic data for purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 notice.

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). For freelance contractors, we maybe required to collect disclosures of previous criminal convictions if a client project requires such disclosures such as projects relating to working with children.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions.You may give us your Identity and Contact Data by requesting further information, filling in forms, using PayPal or by corresponding with us by post, phone, e-mail or otherwise. This includes personal data you provide when you:

— subscribe to our newsletter or publications;

— request a details for further information about our events and services;

— request marketing to be sent to you;

— input information into PayPal or website to create a profile; or

— give us some feedback.

  • Automated technologies or interactions. As you interact with our website and/or PayPal, we may automatically collect Technical Data about your equipment, browsing actions and patterns.

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

— analytics providers;

— advertising networks;

— events organisers;

— search information providers.

4. HOW WE USE YOUR PERSONAL DATA

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 we need to perform the contract we are about to enter into or have entered into with you.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal or regulatory obligation.

See below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

1. To manage our relationship with you which will include:

  • Responding to a request for a quote, or offer of freelance work, or further information about our services

  • Notifying you about changes to our terms or privacy policy

  • Notifying about events

Types of data we will use for this purpose: Identity, Contact, Marketing & Communication,

Lawful basis for processing including basis of legitimate interest:

  • Performance of a contract with you

  • Necessary to comply with a legal obligation

  • Necessary for our legitimate interests (to keep our records updated and to analyse how clients use our services)

 

2. To administer and protect our business and this website and PayPal (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Types of data we will use for this purpose: Identity, Contact, Technical

Lawful basis for processing including basis of legitimate interest:

  • Necessary for our 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)

  • Necessary to comply with a legal obligation

 

3. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we publicise to you

Types of data we will use for this purpose: Identity, Contact, Usage, Marketing & Communication, Technical.

Lawful basis for processing including basis of legitimate interest:

  • Necessary for our legitimate interests (to analyse how clients use our services, to develop our business and to inform our marketing strategy)

 

4. To use data analytics to improve PayPal, our website, services, marketing, client relationships and user experiences

Types of data we will use for this purpose: Usage, Technical.

Lawful basis for processing including basis of legitimate interest:

  • Necessary for our legitimate interests (to analyse how clients use our services, to develop our business and to inform our marketing strategy)

 

5. To make suggestions and recommendations to you about services that may be of interest to you

Types of data we will use for this purpose: Identity, Contact, Usage, Marketing & Communications, Technical.

Lawful basis for processing including basis of legitimate interest:

  • Necessary for our legitimate interests (to develop our business)

 

6. To provide access to, and use of, our booking management system PayPal.

Types of data we will use for this purpose: Identity, Contact, Profile,

Lawful basis for processing including basis of legitimate interest:

  • Performance of a contract with you

  • Necessary for our legitimate interests (or the legitimate interests of our clients)

 

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We do not share your personal data with any company outside the TMR for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us because of a contract for services that you have with us.

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. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purpose:

  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.  We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

6. INTERNATIONAL DATA TRANSFER

TMR will not be transferring any personal information outside of EU.

7. 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, agency or temporary workers, 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 of a breach where we are legally required to do so.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available on request by contacting us.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data (as set out in more detail below), including the right to:

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Object to processing of your personal data.

  • Request restriction of processing your personal data.

  • Request transfer of your personal data.

  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

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 may refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

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

TIME LIMIT TO RESPOND

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 will notify you and keep you updated.

10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

  • Service providers who provide IT, cloud storage, software development and system administration services.

  • Our clients, where you have input your personal data on PayPal, for the purposes of enabling our clients to undertake field reporting.

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide legal, banking, insurance, accounting and consultancy services.

  • Tax authorities, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data 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.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. 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.

Withdraw 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.