NSAN understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.nsan.co.uk (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Site;
“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
[“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]
“Our Site” means our Website and our Membership Platform. For the latter, you must register for an Account.
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the [Data Protection Act 1998] OR [EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”)];
“We/Us/Our” means NSAN, a limited company registered in England under company number 06423637 whose registered address is The Base, Dallam Lane, Warrington WA2 7NG and whose main trading The Base, Dallam Lane, Warrington WA2 7NG.
2. Information About Us
2.1 Our Site is owned and operated by NSAN a limited company registered in England under company number 06423637 whose registered address is The Base, Dallam Lane, Warrington WA2 7NG
2.2 Our VAT number is 924609223
2.3 Our Data Protection Officer is Tricia Austin, and can be contacted by email at firstname.lastname@example.org, telephone number 01925 909700 or by post at The Base, Dallam Lane, Warrington WA2 7NG.
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
- 4.1.1 The right to be informed about Our collection and use of personal data;
- 4.1.2 The right of access to the personal data We hold about you (see section 13);
- 4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 15);
- 4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 7 but if you would like Us to delete it sooner, please contact Us using the details in section 15);
- 4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
- 4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- 4.1.7 The right to object to Us using your personal data for particular purposes; and
- 4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 15 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
5.2 business/company name
5.3 job title;
5.4 contact information such as email addresses and telephone numbers;
5.5 demographic information such as post code, preferences, and interests;
5.6 financial information such as credit / debit card numbers;
5.7 IP address;
5.8 web browser type and version;
5.9 operating system;
5.10 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to;
5.11 Information you provide via our webforms in connection to course enquiries, general enquiries, events etc.
6. How can you control the personal data that we collect on you?
6.1 For all NSAN members registered with us pre-March 2020:
6.1.1 An Account has been created for you on Our Site with information that We already hold with your permission.
- 6.1.2 In creating an Account, you have been auto opted-in to our:
- 188.8.131.52 Group Correspondence from NSAN; correspondence from the groups in which you currently interact under your memberships with us, and
- 184.108.40.206 General Correspondence from NSAN; news and product updates etc.
- 6.1.3 On first login to your account, you will be able to change your communication preferences from Our Site in addition to the personal information that you choose to make visible on your profile to our other members, for example, e-mail address, business phone number etc.
6.2 For all individuals that register on Our Site post March 2020:
- 6.2.1 You will be asked to create an Account and will have sight of the information that We require from you to create this Account, including the option to choose your personal data preferences.
- 6.2.2 Clause 6.1.2 – 6.1.3 will then apply to you as a user.
6.4 Upon registering on Our site, your name and organisation may show in our newest/featured members list on the front-end of our website.
7. How Do We Use Your Data?
7.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
7.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by registering on our Website), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- 7.2.1 Providing and managing your Account;
- 7.2.2 Providing and managing your access to Our Site;
- 7.2.3 Supplying Our products AND/OR services to you (please note that We require your personal data in order to enter into a contract with you);
- 7.2.4 Replying to emails from you;
- 7.2.5 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking on the unsubscribe link at the bottom of all NSAN marketing e-mails.)
- 7.2.6 Market research;
- 7.2.7 Analysing your use of Our Site (and gathering feedback) to enable Us to continually improve Our Site and your user experience;
7.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email OR telephone OR post with information, news and offers on Our products AND services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
7.4 Third parties from our members or our provider network listed and linked from Our Site may use third party Cookies on their websites, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties when visiting their websites.
7.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
7.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- 7.6.1 We keep information, but only as long as we need it for the purposes described above. How long we keep it depends very much on the type of information and purpose.
- 7.6.2 For example, we will keep your information in relation to enquiries for as long as the enquiry is active.
- 7.6.3 If you register for an account via our website you will be auto-opted into our comms (see section 6.1.2) You can opt out of these e-mails at any time by managing your email preferences in your account or by clicking unsubscribe in one of our marketing emails.
If you have signed up to a course that is being organised we will keep your information to communicate with you on the course arrangements. We will also enrol you onto the course using the information that you have provided. In each case, the length of time that we need to keep the information may be different, but we will only keep the information for as long as we need it.
8. How and Where Do We Store Your Data?
8.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
8.2 Your data will only be stored in the UK.
8.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
8.4 Sending information over the internet is generally not completely secure, and we can’t guarantee the security of your data while it’s in transit. Any data you send is at your own risk.
8.5 We have procedures and security features in place to keep your data secure once we receive it.
9. Do We Share Your Data?
9.1 Subject to section 8.2, 8.3 & 8.4, We will not share any of your data with any third parties for any other purposes.
9.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
9.3 If you have completed a course booking form, we will pass on this information entered into the webform to the provider of the course. Through the completion of the web booking form we would deem that you have given permission for this information to be passed to this third party.
9.4 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
10. What Happens If Our Business Changes Hands?
10.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
11. How Can You Control Your Data?
11.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Your Right to Withhold Information
12.1 You may access certain area of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details by using the contact details below in section 14.
15. Contacting Us