privacy policy
we take lots of stuff lightly at THE DEN, but one thing we don't take lightly is your privacy. Scroll down to find out more about what we do with any personal information we collect
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THE DATA PROTECTION OFFICER (DPO) Due to the type of data we collect and the nature of our business we currently have no legal requirement to have a DPO at Denlife LTD. However, we would be happy to deal with any questions you have, and can be contacted through our e-mail address, cheryl@thedenclub.uk or paul@thedenclub.uk or by post to Data Enquiries, Denlife LTD, 29 Woodstock Road, London, SM5 3ED.
INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT We do not require your personal information to use the site. We do not collect sensitive information (also known as special categories of information) about anyone using the site except when you specifically, knowingly provide it and have consented to this. The ‘stay up to date’, ‘get on The List’ and ‘show your support’ functions allow you to give us your contact details to enable us to then keep in touch with you regarding the progress of The Den. We collect information regarding year of birth to allow us to identify children under the age of 18 and ensure we treat them appropriately from a data management point of view. Any personal information related to a child under 13 will be deleted within a few days of receipt. We will also collect any personal information you volunteer to us when we are contacted. We also store some site usage information in Google Analytics.
COOKIES AND WHAT WE DO WITH YOUR INFORMATION This website does not use cookies. We will use your personal information for several purposes including: •To provide personal communications to you in relation to the progress and activities of The Den (Denlife LTD), including information about the activities of key partners. •We may use your personal information to respond to a query by email. We, and any external moderation company, will delete any content submitted which does not comply with our moderation process (for example, content which includes personal information). •We will retain personal data for the purposes that personal information was provided to us. •IP addresses and device identifiers are processed by Google Analytics to enable us to anonymously identify the location of users & establish the number of visits from different countries. More information about the process can be found on Google Analytics’ helpsite. Denlife LTD does not view or store IP addresses and this information is not used for the purposes of identifying individuals. •For analysis and research to improve our services we may use, share and disclose information in aggregate (so no individuals are identified) for marketing and strategic development purposes.
WHAT IF I DON'T PROVIDE SOME OF THE INFORMATION REQUESTED? The impact of this will depend on what information you withhold but the main impacts may be: •We may not be able to respond fully to requests and queries you may have if no contact details are provided •We will assume you are over the age of 18 for data protection purposes if no year of birth is provided
WHAT GROUNDS (LEGAL BASIS) ARE WE PROCESSING THE DATA UNDER? There are a number of grounds we process your data under. These are; •Legitimate interest – this means the processing is in Denlife LTD’s interest. It allows us to improve the services we provide by better understanding how our online provisions are used and which are popular with which groups of individuals. •Consent – where you have given us consent to process your data.
WILL YOU BE CONTACTED FOR MARKETING PURPOSES? We will only use your personal information to update you about the progress of The Den. Any contact for other reasons (for example, to ask your view for research purposes) will be carried out subject to further consent. Consent notifications will be clearly displayed at the point of collection of personal information. We may personalise the message content based on information you provide us with, and your use of The Den website. We may display advertisements served by ourselves. These contextual advertisements would be placed without any Personal Information collected, including persistent identifiers.
QUESTIONS AND RESEARCH CARRIED OUT ON THE WEBSITE We may occasionally ask our visitors questions to gauge their opinions on relevant topics. All information gathered from in questions and research carried out on the site is anonymous and stored as aggregated data. No personal data is collected or stored in this process and the data collected is not used to profile or target visitors as it cannot be linked to an individual. Aggregated and anonymised data may be shared with 3rd parties.
SHARING YOUR INFORMATION WITH THIRD PARTIES We may from time to time provide your personal information to third parties for the purposes providing our services. The third-party providers who help us provide our services include service providers who assist us with hosting the site. Third-party Provider Privacy Policies We use Google Analytics to help analyse your use of the website: •Google’s privacy policy policy is here: https://www.wix.com/about/privacy Our site is powered by Wix: •Wix privacy policy is here: https://www.wix.com/about/privacy We will not provide your data to other third parties for marketing purposes unless you have specifically consented to this when you first provided your data to us.
HOW LONG WE HOLD YOUR DATA FOR We retain anonymised information, gathered for analytical purposes, indefinitely. Data collected by us through the ‘stay up to date’, ‘get on The List’ and ‘show your support’ will be retained for 2 years.
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION Under the Data Protection law, you have a number of rights with respect to your personal information which are: Correcting your Information •You are entitled to have your personal information updated to ensure it is up-to-date and accurate. Withdrawing Consent •You have the right to withdraw your consent to any processing that is currently being done under your consent, e.g. marketing. •Obtaining a copy of your Information •You are entitled to receive a copy of the personal information we hold about you. Deleting your information •You can request that we delete personal information in certain circumstances. These will be specific to each case. Data Portability •You are entitled to have us transfer to another controller the personal information that you have provided us with. Restricting Processing •You can request a restriction on the processing of your data in some limited circumstances. Examples are concerns over data accuracy or we are no longer required to hold your data but you have requested its retention by us to aid you in a legal matter. Right to object to processing •You are entitled to request that we stop processing your data for marketing purposes and in other limited circumstances such as asking us not to process your data by wholly automated means or not to analyse your information for targeted content etc. (also known as profiling). You can action any of these rights by by contacting us through our e-mail address, cheryl@thedenclub.uk or paul@thedenclub.uk or by post to Data Enquiries, Denlife LTD, 29 Woodstock Rd, London, SM5 3ED.
SALE OF THE BUSINESS Should all or part of the Denlife LTD business be sold to or taken over by another organisation, your personal information may move to that other organisation as part of the sale or takeover agreement. The new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use your personal information for the purposes for which it was supplied by you. Your rights regarding your personal information, as laid out above in section 16, will remain unaffected.
RIGHT OF COMPLAINT TO THE REGULATOR FOR DATA PROTECTION The data protection laws in the UK are regulated and enforced by the Information Commissioner’s Office (ICO). Each individual has the right to raise a concern/complaint to the ICO if they have any concerns about how their personal information and/or privacy is treated. You can do this via: •The ICO’s website – follow the links or have an online “live chat” •Call the ICO helpline on 0303 123 1113 •Email casework@ico.org.uk •Postal address: Information Commissioner’s O
LINKS TO THIRD PARTY WEBSITES AND UPDATES TO THIS POLICY Our website may contain links to other websites belonging to third parties which are not covered by this privacy policy. If you want to click through to a third-party website, please make sure that you read the privacy policy for that website. We may update this Policy at any time without notice. We will tell you that we have updated the policy by posting an announcement on the website. By continuing to use the website after we have posted a notice informing you of an update, you accept the changes to this Policy.
ABOUT US www.thedenclub.uk is owned and operated by Denlife LTD (a limited company registered in England with company number 14516755 with its registered office at 29 Woodstock Road, London, SM5 3ED), and we promise to use our best efforts to keep any details you give us private and secure, and we promise not to collect any personal information on you when you use this website. We do not collect website ‘cookies’ but we do use a programme called Google Analytics to understand how people interact with the website and how to make it better. We are committed to protecting your privacy and maintaining the security of any personal information received from you. We strictly adhere to the General Data Protection Regulation 2016 and the Data Protection Act 2018, and we adhere to these acts in all we do.
CONTACTING US If you have any questions about privacy, or wish to update your details or action any of your other data rights at any time, please contact us through our e-mail address, cheryl@thedenclub.uk or paul@thedenclub.uk or by post to Data Enquiries, Denlife Limited, 29 Woodstock Road, London, SM5 3Ed.