Last updated 18/10/2024
This Privacy Policy is governed by the UK General Data Protection Regulation (‘UK GDPR’) and the Data Protection Act 2018 (‘DPA’), comprising the data protection regulations in force in the UK. Guidelines from the Information Commissioner's Office (‘ICO’) have also been adhered to for best practice.
Introduction
Eequ Ltd respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website or use our platform, and tell you about your privacy rights and how the law protects you. Eequ is used by individuals who book learning experiences and activities from a variety of providers. We call these providers ‘Mentors’.
Council Funded Activities and Mentors
Some of our Mentors use Eequ to manage bookings for various Council Funded activity programmes, including but not limited to; the Holiday Activity and Food Programme (‘HAF’), SEND Short Breaks, and Family Hubs.
Council Funded Programmes
As above, our Council Funded programme Mentors receive government funding for their activities. The Council Funded programme is funded by various government departments including the Department for Education (‘DfE’) and is administered by local authorities (‘Councils’).
Eequ has partnered with some of the administering Councils; supplying them with our software to facilitate the booking of Council Funded activities, for eligible children (such as children of families who qualify for benefit related free school meals).
Eequ acts as a Processor for certain Councils and Council Funded Mentors when processing your personal data for Council Funded bookings. Please note, Eequ’s Privacy Policy does not apply to Council Funded data processed by Eequ. To understand how your personal data is processed for the purposes of the Council Funded programme, please refer to your Council’s website where you will find their Privacy Policy.
Special Category Data
In order for us to provide our service, it may be necessary for us to collect and hold Special Category Data in relation to you and/or your child/ren, in line with your Council’s requirements, including but not limited to:·
Health Data (information related to physical or mental health, including special educational needs)
Racial or Ethnic Origin
During the time that we are contracted with your Council, the information we gather or process is used solely for the core functionality of Eequ and to improve the quality and security of our service, as part of our contractual obligation to the Councils we are partnered with. Your information will never be sold to third parties.
Request Deletion of Your Account
We will delete your account upon request. Please note, basic information provided by Mentors about their organisation and listing(s), including but not limited to descriptions and logos, will be preserved. For instance, where a booking has been made. This is also a matter of safeguarding in addition to serving as an audit trail.
How We Use Your Personal Data
Where applicable, Eequ will collect information related to Council Funded Bookings to:
Enable the Council to match eligible children to the benefit related free school meals list or other pre approved list of eligible children (E.g. Looked After Child, Asylum Seeker)
Enable the Council to make discretionary decisions about eligibility for children that fall into categories of other local priorities (E.g. Household Support Fund)
Enable Mentors to assess whether they can meet the needs of the attending children.
Enable the Mentors to allocate the children into the appropriate groups and venues according to their needs.
Enable the Mentors to properly safeguard the children (I.e. awareness of allergies and dietary requirements)
Enable the Mentors to be aware of preferences of the attending children and parents (E.g. choosing a meal option)
Enable the Council to deliver statistical data to the relevant government departments (E.g. the DfE) as relating to their funding requirements or adjacent initiatives.
Enable Eequ to send you transactional emails, for instance where you have booked a Council Funded activity and we need to confirm your booking request has been submitted or update you that your booking has been approved or declined.
Our legal basis for processing the Council Funded programme data is in the public interest or in the exercise of official authority, per Article 6(1)(e) of the UK GDPR. As such, we do not generally rely on consent (Article 6(1)(a) of the UK GDPR) as a legal basis for processing your personal data.
One exception to this is where we will ask for your explicit consent to send third party marketing communications to you via email. You have the right to withdraw consent at any time by contacting us:
Contact Details
Full name of legal entity: Eequ Ltd
Email address: privacy@eequ.org
Postal address: Charter House, Wyvern Court, Stanier Way, Wyvern Business Park, Derby, DE21 6BF
You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues. The ICO’s contact details are linked here. Please note, ICO guidelines recommend that you raise your complaint with us and allow us to address your concerns, before carrying on the complaint to them if you are unhappy with our response.
Continuing with our legal basis, where we process any Special Category Data as above and as exhaustively listed in Article 9(1) of the UK GDPR, it is not sufficient for us to rely upon our lawful basis per Article 6(1)(e) of the UK GDPR. We also rely on Article 9(2)(g) [processing is necessary for reasons of substantial public interest] as we are partnered with the Councils to deliver on the Council Funded programme for the benefit of a section of the public (I.e. those eligible for Council Funded programme).
This is permissible as our processing of your Special Category Data through Article 9(2)(g) is proportionate to our aim of facilitating Council Funded bookings and does not contravene your fundamental rights and interests. Therefore, as we are relying on Article 6(1)(e) in conjunction with Article 9(2)(g), we are permitted to process your Special Category Data without your consent.
Disclosure of your Personal Data
As above, it is necessary for us to disclose your personal data to your Council staff and Mentors.
Data Retention
Eequ will only retain your Council Funded data for the contracted period, with the contracted period referring to the length of the contract we have with your Council to provide our software.
Table of Contents
The below information relates to bookings that are not related to Council Funded programmes. Please note, where a Booker makes a booking containing a Council Funded ticket and a non-Council Funded ticket, the data will be treated separately. The Council Funded ticket data will be governed by the individual Council’s Privacy Policy because we are a Processor as explained above. Correspondingly, the non-Council Funded ticket data will be governed by Eequ’s Privacy Policy).
1. Important Information and Who We Are
2. The Data We Collect About You
3. How We Collect Your Personal Data
4. How We Use Your Personal Data
5. Disclosures of Your Personal Data
6. International Transfers
7. Data Security
8. Data Retention
9. Your Legal Rights
10. Glossary
1. Important Information and Who We Are
Purpose of this Privacy Policy
This Privacy Policy explains how we collect and process your personal data through your use of this website, including but not limited to, any data you may provide to us when you:
Make a booking;
Register your interest for an experience;
Create a listing for a learning experience; Or
Manage bookings made as a Mentor.
Therefore, it applies to all users of our website, such as visitors, Bookers, Mentors, and Learners (attendees of experiences) This Privacy Policy must be read alongside any other Privacy Policy or fair processing policy which we may provide from time to time, when we are collecting or processing your personal data. This is to ensure that you are fully aware of how and why we are using or processing your data.
Please note, this Privacy Policy supplements other notices and privacy policies and is not intended to override them or vice versa.
Controller
Eequ Ltd is the controller and responsible for your personal data (collectively referred to as Eequ, "we", "us" or "our" in this Privacy Policy).
Our ICO registration number is ZA465055. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions and providing responses in relation to this Privacy Policy. Please direct all questions and requests to exercise your legal rights to the DPO via the contact details below.
Contact Details
Full name of legal entity: Eequ Ltd
Email address: privacy@eequ.org
Postal address: Charter House, Wyvern Court, Stanier Way, Wyvern Business Park, Derby, DE21 6BF
You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues. The ICO’s contact details are linked here. Please note, ICO guidelines recommend that you raise your complaint with us and allow us to address your concerns, before carrying on the complaint to them if you are unhappy with our response.
Changes to the Privacy Policy
As per ICO guidelines, our Privacy Policy is reviewed regularly to ensure it is accurate and up to date. Please contact us to obtain historic versions of this policy. You are under no obligation to inform us of changes to your personal data. However, in the interest of maintaining the accuracy of your personal data, please update your account with any such changes as and when they occur.
Third-Party Links
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.
Children
Protecting the privacy of child Learners is of paramount importance at Eequ. We do not collect any information from Learners, and request authority from their parent/guardian (Customer/Booker) before processing any personal data regarding child Learners. We are also required to make reasonable efforts (using available technology) in these circumstances to verify that consent provided on behalf of a child Learner has in fact been provided by the holder of parental responsibility for that child, as is reasonably practicable.
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 which we have grouped together, including but not limited to:
User Account Data: will be collected by us if you choose to log into your Eequ account via a single sign-on option with Facebook, Google or Microsoft.
Mentor Identity Data: First name, last name, username or similar identifier, and date of birth.
Mentor Contact Data: Home address, learning experience address, email address and telephone number(s).
Customer (Booker): Identity Data: First name, last name, and date of birth.
Customer (Booker) Contact Data: Email address, and telephone number(s).
Learner Identity Data: First name, last name, username or similar identifier, date of birth, and relation to Customer.
Mentor Financial Data: Mentor’s bank account and payment card details (we only retain the last four digits and send the complete details directly to Stripe, the payment service provider integrated with Eequ, via an encrypted token.).
Mentor Reflections Data: Reviews of Mentors by Bookers/Learners.
Transaction Data: Details about payments to and from you in relation to bookings made on the platform.
Technical Data: Internet protocol (IP) address, your login data, 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 the platform.
Mentor Profile Data: Username and password, purchases or orders made by you, your interests, preferences.
Customer (Booker) Profile Data: your username and password, bookings and cancellations made by you, preferences, and reviews.
Learner Profile Data: Learners’ learning and dietary preferences, and requirements.
Learner’s Learning Portfolio: Known as ‘The Portfolio’, it comprises a visual representation of bookings which acts as an independently validated record of sessions booked by the Booker/Learner in relation to bookings on Eequ, and may comprise of documents and images relating to the experience.
Usage Data: Information about how you use our platform.
Marketing and Communications Data: Your preferences; if you login via a Facebook, Microsoft, or Google account, we may receive information from them about you, with your express consent. For instance, your public profile and email address. You can stop this by removing our access to Facebook, Google, or Microsoft at any time.
Aggregated Data
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
For instance, we may aggregate your Usage Data to calculate the percentage of users who engage mentors on a repeat basis, or the ratio of learners who attain a certain level of learning progress in respect to certain types of learning experience.
However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this Privacy Policy.
Special Category Data
Our lawful basis [Article 6(1)(f) of the UK GDPR; Legitimate Interests] for processing your data is not sufficient for processing your Special Category Data. Therefore, we will only collect your Special Category Data if you have provided explicit consent per Article 9(2)(a) of the UK GDPR.
Article 9 of the UK GDPR provides special protection for certain types of personal data which are considered to be particularly sensitive. These are known as “special category data”, as follows:
Race;
Ethnic origin;
Religious or philosophical beliefs (including political beliefs and affiliations);
Trade union membership;
Genetics;
Biometrics (where used for ID purposes);
Health;
Sex life; or
Sexual orientation.
Please note, individual Mentors are responsible for complying with prevailing data protection legislation in relation to the data that they process independently.
Failure 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, for instance, to provide you with services.
Illustration 1:
Eequ provides Mentors with a Stripe payment processing account where identification (Know Your Customer) and money laundering checks are made. Where a Mentor is subjected to money laundering checks, Eequ may have to cancel the Mentor’s registration with us, for which we may not be permitted to provide notification by virtue of ongoing investigations instructed by the relevant authorities.
Illustration 2:
Where on a balance of factors, we have reason(s) to believe that an account is fraudulent or nefarious, we may suspend or delete your account without notice. This is done in the interest of safeguarding the Eequ community, of which Children are a significant demographic and must therefore be handled with a higher degree of caution.
3. How Is Your Personal Data Collected?
We use different methods to collect data from and about you, including but not limited to:
Direct Interactions
You may provide your Identity, Contact, and Mentor Financial Data (given to Stripe, our payment processor) predominantly by completing forms online via the Eequ interface. Occasionally, we may have direct interactions by post, phone or email during a support process. This includes personal data you provide when you:
Make (Booker) or accept (Mentor) bookings on Eequ;
Create an account on our website;
Subscribe to our newsletter or promotional updates;
Enter a competition, promotion or survey;
Give us feedback; or
Contact us
Automated Technologies or Interactions
As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using Cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our Cookies. Please see our Cookie Policy for further details.
Our Use of Data Analytics Tools
We analyse platform usage to improve our user experience and ensure stability and performance of our site.
Third Parties or Publicly Available Resources
We will receive personal data about you from various third parties and public sources, including but not limited to: :
Transaction Data from Stripe, the payment services provider integrated into Eequ.
Data from social networks such as LinkedIn, for the purpose of building a Mentor Confidence Score.
Transaction data, as well as Booker and Mentor Contact Data from Intercom, our support channel chatbot, for the purpose of resolving queries. We use this data to prompt you to take actions at various stages. For Instance, to provide additional ID (Mentor) or to confirm your childcare reference number (Booker).
4. How We Use Your Personal Data
The following scenarios outline the circumstances under which we will use your personal data, including but not limited to:
Where we need to perform the contract we are about to enter into or have entered into with you on the basis of our Mentor or Customer (Booker) Terms and Conditions.
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 obligation
Table 4.1 below provides a description of all the ways we use or plan to use your personal data, alongside the legal bases we rely on to do so. Please note, we may process your personal data for more than one lawful basis depending on the specific purpose. Please contact us using the contact information above, if you would like us to specify the exact legal basis we are relying on to process your personal data, where more than one basis has been set out.
Table 4.1
Purpose/Activity | Type of Data | Lawful Basis (UK GDPR, Article 6) |
1. To register you as a new Customer or Mentor | (1) Identity (2) Contact (3) Facebook/Google/ Microsoft Login | Article 6(1)(b): Performance of a contract with you. |
2. To process your booking on Eequ | (1) Identity (2) Contact (3) Financial (4) Transaction (5) Marketing and Communications | Article 6(1)(b): Performance of a contract with you
Article 6(1)(f): Necessary for our legitimate interests |
3. To manage our relationship with you which will include notifying you about changes to our terms or Privacy Policy and/or asking you to leave a review about a Mentor experience, or take a survey | (1) Identity (2) Contact (3) Profile (4) Marketing and Communications | Article 6(1)(b): Performance of a contract with you
Article 6(1)(c): Necessary to comply with a legal obligation
Article 6(1)(f): Necessary for our legitimate interests (to keep our records updated and to study how Mentors and Customers use our service) |
4. To administer and protect our business and the website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (1) Identity (2) Contact (3) Technical | Article 6(1)(f): 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)
Article 6(1)(c): Necessary to comply with a legal obligation |
5. To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we employ | (1) Identity (2) Contact (3) Profile (4) Usage (5) Marketing and Communications (6) Technical | Article 6(1)(f): Necessary for our legitimate interests (to study how customers use our Eequ services, to develop them, to grow our business and to inform our marketing strategy) |
6. To use data analytics to improve our website, Eequ services, marketing, customer relationships and experiences | (1) Technical (2) Usage | Article 6(1)(f): Necessary for our legitimate interests (to define types of learners, customers and mentors for our Eequ services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
7. To use data analytics to make recommendations or suggestions regarding potentially suitable experiences or opportunities for Learners. | (1) Identity (2) Contact (3) Profile (4) Usage (5) Marketing and Communications (6) Technical (7) Transaction | Article 6(1)(f): Necessary for our legitimate interests (to study how customers use our Eequ services, to develop them, to grow our business and to inform our marketing strategy) |
8. To make suggestions and recommendations to you about goods or services (such as new Mentors) that may be of interest to you | (1) Identity (2) Contact (3) Technical (4) Usage (5) Profile (6) Marketing and Communications | Article 6(1)(f): Necessary for our legitimate interests (to develop our Eequ services and grow our business) |
Promotional Communications From Us
If you have opted into our mailing list, we may use Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think a Learner may want or need, or what may be of interest to a Booker and/or Learner.
You will receive communications from us suggesting or promoting specific experiences, if you have opted into our mailing list, for instance.
Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes, in accordance with Article 6(1)(a) of the UK GDPR. Furthermore, we make it possible for you to receive marketing information from Mentors you are interested in, by obtaining your consent via our check out questionnaire as part of the booking process.
Opting Out
You can ask us or third parties to stop sending you marketing messages at any time. You can do this by clicking the ‘Unsubscribe’ link at the bottom of all Eequ marketing emails or by contacting us using the contact information. However, there is no option to opt out of transactional emails such as booking confirmation emails, as they are essential to deliver the service. Please note, if the marketing has been sent by the Mentor directly as a third party, you must contact them directly to opt out.
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
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 using the contact information.
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, where this is required or permitted by law.
5. Disclosures of Your Personal data
We may share your personal data with the parties set out below, for the purposes listed in Table 4.1 above:
If you are a Customer or a Learner, we share your data with Mentors to the extent necessary to facilitate and administer your booking.
If you are a Mentor, we share your data with visitors to the Eequ website so that they can view your listing; we also share your data with Customers and Learners to the extent necessary to facilitate and administer your booking.
Stripe, the payment services processor integrated with Eequ, based in Dublin and the US, which facilitates payouts to Mentors who process paid bookings.
Intercom (EU data residency), which powers our support channel.
Google Analytics, an industry standard third party analytics platform that we use to understand the usage and performance of our services. The information is anonymised.
Nolt (EU data residency), which collects feature requests and reports of bugs from users.
Slack (UK data residency), which conveys internal operational messages at Eequ.
Gmail (EU data residency), which facilitates internal communications.
Sendgrid (EU data residency), which is used for transactional emails.
Google Drive (EU data location), which facilitates internal communications.
Linear (EU data location), which is a project management tool for internal projects and strategy at Eequ.
AWS (UK data location), which provides cloud servers in the UK for Eequ.
IT Contractors, based in the UK and Europe, who provide software development services, and IT and system administration services.
Insurance providers (UK based), which we may provide certain information to, to help set up your account with them. This is in the event that we integrate an insurance provider for learning experiences on Eequ.
Professional advisers (UK based), such as lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
HM Revenue & Customs, regulators, and other authorities, which require reporting of processing activities in certain circumstances.
Third parties listed in Table 4.1, for the corresponding purposes listed within said table.
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. In the event of such a change, the new owners may use your personal data only as set out in this Privacy Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
6. International Transfers
ICO guidance mandates transparency on international data transfers, as Eequ is a UK-based organisation subject to the UK GDPR. Please note, transfers between the UK and the European Economic Area (EEA) can continue without additional safeguards due to the UK's adequacy decision. However, transfers outside the EEA entail further requirements.
As above, one of the third parties we disclose data to is Stripe, our payment processor, whose data residency is in Europe and the US. Stripe ensures that data for European customers is stored in compliance with GDPR requirements. This typically involves using data centres located in the EU for EU-based customers to minimise cross-border data transfer issues.
However, as Stripe does not offer direct options for Eequ to manually choose our data residency, and employs global infrastructure with servers across multiple regions, there is a potential international transfer of data to the US.
Nevertheless, Eequ’s partnership with Stripe is permissible:
The international transfer of data (restricted transfer) is permissible if it is covered by ‘adequacy regulations’. Specifically, for the US, there have been partial findings of adequacy. It is described as partial adequacy because it only covers data which is transferred under the UK Extension to the EU-US Data Privacy Framework (“EU-U.S. DPF”). Stripe has certified its participation in the UK Extension to the EU-U.S. DPF.
Although the above reason justifies the restricted transfer, our partnership with Stripe would still be permissible where there was no such adequacy decision. This is because Stripe further employs appropriate safeguards (Article 46 of the UK GDPR). In order for any of these safeguards to apply, it is a precondition for Eequ to undertake a transfer risk assessment, to affirm that the relevant protections in the UK GDPR are not undermined for our users whose data is being transferred.
Stripe’s specific Article 46 transfer mechanism (I.e. the appropriate safeguard) is the ‘Standard data protection clauses’, specifically the International Data Transfer Agreement (IDTA). Having taken into account the protections contained in Stripe’s Article 46 transfer mechanism, and considering the protection afforded to data subjects in the destination country (US), we can confirm that the protections afforded to our users by virtue of the UK GDPR are not undermined.
For more information, please visit Stripe’s GDPR compliance page.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, accessed, altered, or disclosed in an unauthorised way. 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 manage 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
We will only retain your personal data for as long as reasonably necessary to fulfil the purpose(s) we collected it for, including for the purpose 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.
To determine the appropriate retention period, we assess several factors, including but not limited to:
The amount, nature and sensitivity of the personal data;
The potential risk of harm from unauthorised use or disclosure;
The purposes for which we process your personal data and whether we can achieve those purposes through other means; and
The applicable legal, regulatory, tax, accounting, or other related requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us using the contact information above.
By law we have to keep basic information about Mentors and Customers (Bookers and/or Learners), including Transaction Data, for six years after they cease being Customers for tax purposes. In some circumstances, you can ask us to delete your data as explained below. We may also anonymise your personal data for research and/or statistical purposes, in which case we may use this information indefinitely without providing further notice to you.
9. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are as follows:
Right to Be Informed and Right to Withdraw Consent
Right of Access
Right to Rectification
Right to Erasure
Right to Object
Right to Restrict Processing
Right to Data Portability
1. Right to be Informed and Right to Withdraw Consent
You have the right to be informed about the collection and use of your personal data. This is a key transparency requirement under the UK GDPR which is met throughout our Privacy Policy. Please note, this right is always applicable, regardless of our lawful bases, namely Article 6(1)(b), (c), and (f) of the UK GDPR, as indicated above in Table 4.1.
You may 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 our services to you. We will advise you if this is the case at the time you withdraw your consent.
You may exercise this right in connection with our lawful basis under Article 6(1)(a) of the UK GDPR [Consent] or as a standalone right per Article 7(3).
2. Right of Access
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.
You may exercise this right in connection with our lawful basis under Article 6(1)(b) of the UK GDPR [Contractual Relationship], as well as Article 6(1)(c) [Legal Obligation] and Article 6 (1)(f) [Legitimate Interests].
3. Right to Rectification
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, although we may need to verify the accuracy of the new data you provide to us.
You may exercise this right in connection with our lawful basis under Article 6(1)(b) of the UK GDPR [Contractual Relationship], as well as Article 6(1)(c) [Legal Obligation] and Article 6(1)(f) [Legitimate Interests].
4. Right to Erasure
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where you are using one of the reasons in the ICO guidance. 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 the law.
Please 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.
You may exercise this right in connection with our lawful basis under Article 6(1)(b) of the UK GDPR [Contractual Relationship] and/or Article 6(1)(f) [Legitimate Interests]. Please note, for the former basis, your right may be limited if the data is still necessary for fulfilling the contract. For the latter, your right may be restricted if we have overriding legitimate interests in keeping the data.
5. Right to Object
You have the absolute right to object where we are processing your personal data for direct marketing purposes. Regarding other purposes, you can 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 may exercise this right in connection with our lawful basis under Article 6(1)(f) of the UK GDPR [Legitimate Interests]. Please note, this right may be restricted if we have compelling grounds for the processing that override your interests, rights, and freedoms.
6. Right to Restrict Processing
Request restriction of the processing of your personal data. 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, pursue, or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
You may exercise this right in connection with our lawful basis under Article 6(1)(b) of the UK GDPR [Contractual Relationship], as well as Article 6(1)(c) [Legal Obligation] and Article 6 (1)(f) [Legitimate Interests]. Please note, for Article 6(1)(c), your right may apply in limited situations, especially when the accuracy of the data is contested.
7. Right to Data Portability
One request you may make under this right is to request the transfer of your personal data to yourself or to a third party. We will provide to you and/or a third party of your choosing, your personal data in a structured, commonly used, and machine-readable format.
Please note, 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.
You may exercise this right in connection with our lawful basis under Article 6(1)(b) of the UK GDPR [Contractual Relationship].
If you wish to exercise any of the rights set out above, please contact us using the contact information above. Please note:
1. 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 could refuse to comply with your request in these circumstances.
2. 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.
3. Time limit to respond
ICO guidelines indicate that we have one month (or a maximum of three months, for complex Right to Object requests) to respond to your request. If we anticipate that our response will exceed the one month time frame (where it is permitted), we will inform you of the reason for the extension within the initial one month timeframe.
10. Glossary
“Lawful Basis” refers to a valid reason for us processing your data. These valid reasons are set out in Article 6 of the UK GDPR. The UK GDPR and ICO guidance requires us to have a valid lawful basis for each processing activity and we have set this out accordingly throughout this Privacy Policy.
“Legitimate Interests” refers to the interests of our business in conducting and managing our business, to enable us to give you the best service and the most secure experience on Eequ. 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 using the contact information above.
“Performance of Contract” refers to us 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, or as are reasonably necessary before entering into such a contract.
“Comply with a legal obligation” refers to us processing your personal data as a result of a legal obligation that we are subject to.