1. INTRODUCTION
    1. We are committed to protecting and respecting your privacy.
    2. This policy applies between globalbridge Limited of Clavering House, Clavering Place, Newcastle upon Tyne, NE1 3NG (we or us) and you. We are the data controller and are responsible for your personal data.
    3. This policy (together with our Terms of Use and Acceptable Use Policy and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it. By using our website, www.globalbridge.org.uk, and any of our services, you are accepting and consenting to the practices described in this policy.
    4. On other specific occasions, we may issue additional privacy notices or fair processing notices to you when we are collecting or processing your personal data for other purposes. This privacy policy supplements the other notices and is not intended to override them.
  2. CONTACT DETAILS
    1. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.
      1. Email address: admin@globalbridge.org.uk
      2. Postal address: Clavering House, Clavering Place, Newcastle upon Tyne, NE1 3NG.
  3. DATA WE MAY COLLECT FROM YOU
    1. 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). It can however include Special Categories of Personal Data, as further detailed below.
    2. We may collect and process the following personal data about you:
      1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, photographs, personal descriptions, passport number and national insurance number.
      2. Contact Data includes billing address, residential address, email address and telephone numbers.
      3. Financial Data includes financial, bank account and payment card details.
      4. Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
      5. Technical Data includes 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 this website.
      6. Profile Data includes your username and password, purchases made by you, your interests, preferences, feedback and survey responses.
      7. Usage Data includes information about how you use our website and services.
      8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
    3. We also collect, use and share Aggregated Data such as statistical or demographic data for any 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.
    4. We will only collect Special Categories of Personal Data about you to carry out our service with your explicit consent (for example, when you choose to provide Special Categories of Personal Data when using our services or when creating a profile on our Site). 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.
    5. References in this policy to your personal data shall include any Special Categories of Personal Data that we may also collect, process and store about you. For the avoidance of doubt, should you provide such Special Categories of Personal Data when you are creating a profile on our Site, you accept that this may be published as part of your profile for other users of our Site to view.
  4. IF YOU FAIL TO PROVIDE DATA
    1. 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 example, to provide you with our services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
  5. HOW WE COLLECT DATA ABOUT YOU
    1. Information you give us. You may give us information about you by filling in or updating information about yourself on the Site (your Profile) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use the Site, complete your Profile, provide information about yourself on the Site, subscribe to our services, use search facilities on the Site or other functions on the Site, report a problem with the Site and request marketing to be sent to you.
    2. Information we collect about you. With regard to each of your visits to the Site we may automatically collect the following information:
      1. technical information, including the Internet protocol address used to connect your computer and devices to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
      2. information about your visit (including date and time); products you viewed or searched for; names that you searched for; profiles that you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
    3. Information we receive from other sources. We may receive information about you if you use any websites we operate or any other services we provide. We also work closely with third parties (including, for example, business partners, recruitment agents, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and we may receive information about you from them. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out in Clause 7 below.
  6. COOKIES
    1. We use cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse the Site and also allows us to improve the Site. For detailed information on the cookies we use and the purposes for which we use them, see our Cookies Policy.
  7. USES MADE OF THE DATA
    1. We will only use your personal data when the law allows us to. Most commonly, we will use information held about you in the following ways:
      1. Where we need to perform the contract we are about to enter into or have entered into with you.
      2. 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.
      3. Where we need to comply with a legal or regulatory obligation.
      4. Where you have provided your explicit consent.
    2. We have set out below, in a table format, a description of all the ways we may 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.
    3. Note that we may process your personal data for more than one lawful ground epending 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.
    4. Any Special Categories of Personal Data shall be processed only with your explicit consent (as described earlier in this policy) and the lawful ground descriptions set out in the below table shall not be deemed or otherwise interpreted to vary such requirement.
  8. Purpose/Activity Type of Data Lawful Basis for Processing Including Basis of Legitimate Interest
    To register you as a user, to carry out our obligations arising from any contracts entered into between you and us (or, where you are an individual student or parent, any contract which your school or educational establishment has entered into with us) and to provide you with the information, products and services that you request from us.
    1. Identity
    2. Contact
    1. Performance of a contract with you
    2. Consent
    3. Necessary for our legitimate interests (for running our business)
    To provide you with information about other services we offer that are similar to those that you already use or have enquired about.
    1. Identity
    2. Contact
    3. Marketing and Communications
    Necessary for our legitimate interests (to develop our products/services and grow our business)
    To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you.
    1. Identity
    2. Contact
    3. Marketing and Communications
    A specific consent will be requested if we are to provide this service.
    For analytical purposes to help us to filter and categorise the profiles on the Site (including, without limitation, use for research and statistical purposes), this may include using geo-demographic information from outside sources.
    1. Technical
    2. Usage
    Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
    To notify you about changes to our service including its suspension and maintenance.
    1. Identity
    2. Contact
    3. Technical
    1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)
    2. Necessary to comply with a legal obligation
    To ensure that content from the Site is presented in the most effective manner for you and for your device.
    1. Technical
    2. Usage
    Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)
    To ensure that content from the Site is presented in the most effective manner for you and for your device.
    1. Technical
    2. Usage
    Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)
    To deal with your requests and enquiries.
    1. Identity
    2. Contact
    1. Performance of a contract with you
    2. Consent
    To deliver our services, which will include making it available to our Members (being Educational Establishments, Employers and/or other Institutions).
    1. Identity
    2. Contact
    1. Performance of a contract with you
    2. Consent
    To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
    1. Identity
    2. Contact
    3. Technical
    1. 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)
    2. Necessary to comply with a legal obligation
    To create a personalised user experience for you, in presenting you with recommendations regarding services that you may wish to purchase.
    1. Identity
    2. Contact
    3. Technical
    4. Usage
    5. Profile
    Necessary for our legitimate interests (to develop our products/services and grow our business)
    To allow you to participate in interactive features of our service, when you choose to do so (if applicable).
    1. Identity
    2. Contact
    3. Profile
    4. Technical
    1. Performance of a contract with you
    2. Consent
    3. Necessary for our legitimate interests (for running our business)
    To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you (if applicable)
    1. Identity
    2. Contact
    3. Profile
    4. Usage
    5. Marketing and Communications
    6. Technical
    Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
    To process and deliver payments and to recover money owed to us.
    1. Identity
    2. Contact
    3. Financial
    4. Transaction
    5. Marketing and Communication
    1. Performance of a contract with you
    2. Necessary for our legitimate interests (to recover debts due to us)
  9. MARKETING
    1. We will strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Please note that your personal data will only be used for marketing and advertising purposes if we have specifically asked for, and you have provided, your express consent. When such consent has been provided the terms of this Clause 8 shall apply.
    2. We may use your Identity, Contact, Technical, Usage and Profile 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 products, services and offers may be relevant for you (we call this marketing).
    3. You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
    4. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
    5. You can ask us or third parties to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences or by contacting us at any time.
    6. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transaction.
  10. CHANGE OF PURPOSE
    1. 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.
    2. 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.
    3. 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.
  11. DISCLOSURE OF YOUR INFORMATION
    1. We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and subsidiaries, as defined in Section 1159 of the UK Companies Act 2006.
    2. You agree that we may share your information with selected third parties including:
      1. Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
      2. Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to a target audience;
      3. Analytics and search engine providers that assist us in the improvement and optimisation of the Site; and
      4. Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
    3. You agree that we may disclose your personal information to third parties:
      1. In the event that we sell any part or parts of our business or its assets, in which case we may disclose your personal data to the prospective buyer of such business or assets;
      2. In the event that we acquire a business or the assets of a business to be operated by us we may utilise your personal data in the use of such business or assets;
      3. If the whole or substantially all of our assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets;
      4. 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 our Terms of Use and/or Acceptable Use Policy and other agreements; or
      5. To protect the rights, property, or safety of the Site, our customers, or others; this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
    4. Your data will not be disclosed to third parties as outlined in Paragraphs 10.2 and 10.3 above if you have opted-out by ticking the relevant box or boxes on an application form or by contacting us.
    5. 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.
  12. CHILDREN
    1. If your Profile is to be submitted to us whilst you are attending primary or secondary education, it will need to be reviewed with you by the educational establishment you are attending or your parents/guardians alongside this policy before such submission is completed. We want to be assured that you have fully understood our service and how we may use your personal data so, whilst you will be asked to confirm (using an unticked box) that you have read and understood this policy, we may still check with your educational establishment that such review has taken place.
    2. If you are submitting your Profile directly to us (not through an educational establishment), then it is necessary that you supply your date of birth if you are under the age of 18. In some circumstances we may also require the consent of your parent or guardian before we accept your Profile.
  13. INAPPROPRIATE AND OFFENSIVE CONTENT
    1. If we receive any material, or such is posted by you by way of an addition to your Profile or other record of yourself held by us, or such content or information or material is about another person, and we consider that to be offensive, inappropriate or objectionable we reserve the right to remove that material and may suspend your use of the programme.
  14. WHERE WE STORE YOUR PERSONAL DATA
    1. All information you provide to us is stored on secure servers with Amazon Web Services (AWS), [which are based within the United Kingdom.]
    2. From time to time your personal data may also be processed by staff operating outside the European Economic Area (EEA) who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
    3. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
    4. You agree that we may disclose your personal information to third parties:
      1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
      2. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
      3. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
    5. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
    6. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
    7. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
  15. THIRD-PARTY LINKS
    1. 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 notice of every website you visit.
  16. DATA SECURITY
    1. 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.
    2. 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.
  17. DATA RETENTION
    1. We will hold all relevant personal data in accordance with the General Data Protection Regulation ((EU) 2016/679) as it may be implemented into national law (and any other data protection legislation in force from time to time). 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.
    2. 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.
    3. Details of retention periods for different aspects of your personal data are available on request from us by contacting us. However, we will usually contact you at least once in every 12 month period to confirm that your personal data is up to date. You are advised to check your email account regularly to see if we have sent you any such emails. If we have not heard from you after a period of 24 months, your Profile and personal data may be deleted but we will first contact you by email to notify you of this intention to give you the opportunity to update the personal data or advise us if you wish your Profile to remain. In addition, in the event of your death your personal data will usually be held by us for a period of no more than 12 months after being notified of your death and then permanently and securely destroyed or deleted.
  18. YOUR LEGAL RIGHTS
    1. You have the right to:
      1. 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.
      2. 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.
      3. 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.
      4. 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. You can exercise your right to prevent such processing by not checking certain boxes when registering to use the Site and/or completing or updating your Profile. That is to say if you check a box you are agreeing to your data being so processed.
      5. 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.
      6. 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.
      7. 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.
    2. If at any time you are concerned that your information held by us may have been compromised in any way or been accessed by a person or persons or company or business without your consent having been given will you please get in touch with us immediately in order that we can investigate further and take any necessary steps needed to protect your information.
    3. 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 contact us in the first instance.
  19. ACCESS TO INFORMATION
    1. You will not have to pay a fee to access your personal data (or to exercise any of your 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.
    2. 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. 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.
  20. CHANGES TO OUR PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
    1. Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
    2. 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.
  21. CONTACT
    1. Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to admin@globalbridge.org.uk.