PRIVACY POLICY

PRIVACY POLICY

Last updated: 10th December 2023

Who are we

The Website is owned and/or operated by Hope 4 The Community CIC, a company registered in England and Wales under company number 09397915, with a registered office at The Enterprise Hub, 5 Whitefriars street, Coventry, CV1 2DS (‘We’, ‘Us’, ‘Hope 4 The Community’ or ‘Hope For The Community’ or ‘H4C’). 

H4C is the data controller and our Data Protection Officer, Gabriela Matouskova, can be contacted via dpo@h4c.org.uk.

Definitions

  • ’Data Protection Legislation’ means the General Data Protection Regulation (EU Regulation 2016/679), the Data Protection Act 2018 and/or any subsequent data protection legislation which replaces such laws and regulations.

  • 'Member' means an individual that has registered as such on the Website and has had a Member Account set up on the Website

  • ‘Member Content’ means any information that a Member enters or uploads to the Website, excluding Profile Information entered to register, but including information entered to activate an account, in the Profile sections of the Website, in page Discussion Topics, any Activities and the Forum.

  • ‘Course Profile’ means the username you select to identify yourself to other Members and which will be available to Facilitators.

  • ‘Personal Information’ means information that relates to an identified or identifiable individual.

  • ‘Profile Information’ means information that identifies individuals, including You and others, e.g. real name, email address, gender, post code, telephone number, and date of birth.

  • 'Website' means the websites located at https://hopeprogramme.coventry.ac.uk and/or https://www.h4c.org.uk/.  It also includes the Hope Programme mobile apps (Webapp, Ios, Android).

  • 'Terms' means the terms and conditions for use of the Website which incorporate this Privacy policy.

  • 'You' means you, the user of the Website and 'Your' and 'Yourself' shall be interpreted accordingly.

  • Website “The Community” means the area of the Website where You can post and interact with other users, including trained volunteers and professionals.

  • “Facilitators” means trained volunteers or professionals assigned by Hope For The Community CIC to provide guidance to Members.

Our privacy commitment

We take Your privacy rights very seriously and seek to ensure the highest standards of compliance with the Data Protection Legislation. Our main aim is to provide a safe place for you to share your thoughts, feelings and discussions with others in a confidential environment, where your anonymity is respected.

Our Privacy Policy explains how We collect, use, disclose and retain Your Personal Information and how You can protect Your privacy when You use the Website.

By accessing and continuing to use the Website, You accept the terms of this Privacy Policy.

Changes to our privacy policy

Please note that We may update and amend Our Privacy Policy from time to time and We will post any changes on the Website. We may notify you of changes by email but it is Your responsibility to check regularly if there have been changes and to review such changes. We will indicate with a “last updated” date at the top of the Policy when Our Privacy Policy was last revised. If You do not agree with any of Our Privacy Policy then You are not permitted to use the Website. If you have any queries or complaints in relation to Our Privacy Policy then you can contact us using the information under the ‘Contacting Us’ section below.

Contacting us

If You have any questions, concerns or suggestions about Our privacy practices, please email Our Chief Executive Officer at contact@h4c.org.uk . Please remember to protect Your privacy if You contact Us, e.g., do not include information about Your health or Your Course Profile or other information from any Member Content that you provide anonymously. Regular email is never a secure method of communication.

Protecting your privacy and identity

Our main aim in providing the Website is to provide a safe place for You to share Your thoughts, feelings and discussions with others in a confidential environment, where Your anonymity is respected.

We use appropriate administrative, physical and technical safeguards to protect Your Personal Information from loss or theft, unauthorized access, use or disclosure, or modification or destruction. For example, We train Our personnel to protect Your privacy and require them to comply with Our policies and procedures that protect Your Personal Information. We use computing systems in secure facilities to store and transport Your Personal Information in an encrypted form. Where we process your data for research purposes or statistical purposes we present results anonymously or in aggregated form so that individuals cannot be identified.

Unfortunately, the transmission of information via the internet is not completely secure. Although We will do Our best to protect Your Personal Information, We cannot guarantee the security of Your Personal Information transmitted to the Website; any transmission is at Your own risk.

Should you become a Member, You will be given Your own profile page which will grow and develop the more you use the Website. You also play an important role in protecting Your Personal Information and Member Content. For example:

  • Create a strong, unique password for the Website using a combination of letters, numbers, and special characters. Avoid easily guessable information, such as names or birthdays.

  • You must keep Your password for the Website confidential. We ask You not to share Your password with anyone.

  • Use an email account to which only You have access to receive emails and notifications from Us.

  • Consider enabling two-factor authentication on Your email account for an additional layer of security.

  • If You access the Website from a shared device, remember to log out. Close the browser or application after logging out.

  • Keep Your devices secure by using device passcodes or biometric authentication. Regularly update Your device software to ensure the latest security patches are applied.

This Website is intended for users aged 18 years or older. If you are aware of users less than 18 years old accessing the Website and providing personal data, without parental consent, please let us know at contact@h4c.org.uk.

Please be aware there is a risk that Members could identify You from information You post on the Website. If you wish to protect Yourself:

  • When you set up your Profile Choose a Course Profile name that is not related in any way to Your real name or nickname. Other Members will see Your Course Profile name. Also choose to leave your profile image as the default icon or select from the library of avatars that is not related in any way to Your real gender, ethnicity or resemblance.

  • Do not post on the public areas of the Website details such as Your real name, names of family members or friends, place information, e.g., where you live, where You receive healthcare or places You like to visit, Your phone number or Your e-mail address.

Privacy Settings

The Website has privacy settings that You may use to protect Your identity. For example:

  • Posts. In the ‘Posting preferences’ section of Contact preferences, You can control who sees Your posts on the course (Everyone – Facilitators – Just me). You may change these settings at any time, but please be aware that some previously entered Member Content may still appear in archived or cached pages.

  • Facilitators You can choose how to interact with your facilitator (via private messaging).

  • If you do not use Our privacy settings, other Members will see the Member Content You post with Your Course Profile beside it.

How we collect and use Profile Information

Depending upon Your use of the Website, We may collect and use Your full name, date of birth, gender, post code, telephone number and email address (which is Profile Information) to:

  • Register You: We collect Your first name, last name and an email address as a minimum to register You and create Your Member account. More particularly, We use Your date of birth to confirm Your eligibility for Membership. If You have registered using your post code, we will also collect this information to confirm Your eligibility for Membership. The gender information enables us to report on our inclusivity and social impact of our programmes.  If you register for a course, you cannot opt-out of this processing.

  • Administer the Website and Your Membership: If You enter Your email address when You login, We will use it to authenticate You. We use Your Profile Information to present it to You in ‘Your Account’. We may also use Your Profile Information to:

○ Investigate any suspected breaches of, and enforce Our Terms.
○ Process and deal with any complaints made by or about You.
○ Process and deal with any IT support requests made by You.
○ Investigate usage of the Website that may be inappropriate.
○ Comply with any legal obligation.
○ Seek compensation from you or take other action including legal action as set out in the Terms.

You cannot opt-out of this processing while you have an active account on the Website.

  • Communicate with You: We email you messages about the Website and/or Your Membership, and notifications about new content and activity on the Website pertinent to You, e.g., that You have received a private message. If You do not wish to receive notifications, You may turn them off in the ‘Contact Preferences’ section of the Website. You may also unsubscribe from marketing emails by clicking unsubscribe links within those emails or letting us know at contact@h4c.org.uk.

  • Respond to You: If you email Us, We will collect and use any Profile Information You provide to Us to process and respond to Your message. If You request a password reset or other support, We will email You instructions and information to help resolve Your request.

From time to time, We may collect additional Personal Information from You when You provide it. For example, We may present a research survey to You within the Website and collect Personal Information from You if You agree to participate. This information may include special category data, such as health and ethnicity data. 

When We collect additional information, this is optional and where relevant we inform You about why We wish to collect Your Personal Information. We limit Our collection of Personal Information to what is necessary for the purposes for which We wish to collect, use or disclose it.

We may use Your Personal Information to create reports and data that contain information that cannot be used to identify You. We use such reports and data, and may disclose them to external parties, such as funding sources, for: statistical, analytical and reporting purposes; research; and for evaluating and enhancing the Website or improving the service. For example, We may produce reports that identify how many Members live in different geographical areas by using Your postal code along with that of other Members.

How we collect and use Member Content

Please be aware that you could provide Member Content that would identify you to other Members or course facilitators. We may delete any Member Content if We believe that it will reveal your identity to others.

We use and disclose Member Content to:

  • Present the Member Content to You when You visit the Website.

  • Customize content that We present to You on the Website, or in emails and notifications that We send to You and other Members. For example, We may include Your Course Profile when We notify another Member that You have sent them a private message.

  • Monitor, develop and improve the Website, and optimize Your experience of them.

  • Create reports and data for: statistical, analytical and reporting purposes; research; and for evaluating and enhancing the Website. We may disclose such reports and data to external parties, including funders. For example, We collect and use the information that You enter to activate Your Account to create aggregate, anonymous information or reports about Membership and usage of the Website.

  • Other Members have no access to the Member Content You provide when You activate Your account, or enter into Your Profile or Profile. Other Members may view Your Course Profile and the Member Content You provide in Newsfeed and Online Forums, subject to Your privacy settings. (Please see the section above ‘Privacy Settings’ on how to set and change Your privacy settings.) Our Facilitators may view the Member Content You provide in any Newsfeed and Online forum posts, along with Your Course Profile. Our Facilitators only have access to anonymous content and do not have access to your Your Profile Information, including Your email address.

  • Comply with any legal obligation.

You cannot opt-out of this processing of your content while you have an active account on the Website.

Special category information

You may give us special category or sensitive Personal Information such as biometric data for unique identification, health information and medical records, racial or ethnic origin, political orientation or beliefs, religious or philosophical beliefs, trade union membership, data concerning sex life or sexual orientation.  We use this data to produce anonymous or aggregated statistical reports. 

Providing this information is optional. If you provide this information and subsequently want to opt-out of this processing, please contact us at contact@h4c.org.uk

Information about other individuals

If You give Us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that You can:

  • give consent on his/her behalf to the processing of his/her Personal Information;

  • receive on his/her behalf any data protection notices; and

  • give consent to the transfer of his/her Personal Information as contemplated in this Privacy Policy.

This information is particularly relevant to referring organisations such as the NHS or Macmillan Cancer Support.

Information that the site automatically collects

Our webservers automatically collect information about Your visit to the Website including, but not limited to, traffic data, location data, weblogs and other communication data. Although We do not ordinarily set out to identify You from Your Internet Protocol (IP) address, We treat IP addresses as Personal Information. We may use data that Our webservers automatically collect about Your use of the Website, including IP addresses, to investigate any suspected breaches of Our Terms.

We use information automatically captured by Our web servers that is not Personal Information to see how the Website is being used and customize it for Your benefit.

Legal basis for processing Your Personal Information

We process your personal information based on Your consent which You give by clicking ‘I accept’ during the registration process and again when accessing the Website.  You may withdraw Your consent and request that We cease processing your data by contacting contact@h4c.org.uk.

In the event We share your Personal Information with health and safeguarding organisations the legal basis will be that it is necessary for the purpose of a recognised legitimate interest. 

Where we process special category data We do so on condition that you have given Your explicit consent (UK GDPR Art 9(2)(a) and that we are processing it for research and statistical purposes (Art 9(2)(j)).

If we change the purposes of processing your data by consent, we will inform you and ask you to re-confirm your consent.

How we may disclose your Personal Information

We do not share or disclose any of your Personal Information without your consent, other than for the purposes specified in this policy.

We may need to share your data with other service providers in order to facilitate the running of the Website. For example, third parties associated with developing and supporting the Hope platform. When this happens, we implement strict contractual agreements with such third parties limiting the use of your data to activities specific to the Website.

Details of the third parties that process your data with are set out below

Magic Square Systems Ltd: Development, technical improvements to the Website, technical support, and facilitating data migration to alternative hosting services.

We may also disclose Your Personal Information to third parties:

·       if We are required to do so by law;

·       in order to enforce or apply Our Terms and other agreements;

·       if it is necessary for the purpose of a recognised legitimate interest or

·       to protect the rights, property, or safety of Hope 4 The Community CIC, Our customers, or others.

This includes exchanging information with other companies and organisations such as the police, healthcare providers, regulatory bodies or legal advisers for the purposes of safeguarding, security, risk reduction and fraud protection.

Marketing

When (and only when) requested by You, and only to the extent requested by You, we will also use Your data to send You and keep You updated with information by e-mail or message through the Website about existing and new services and special offers from Us and to send you information by e-mail or message through the Website about related products or services of selected third parties that may be of interest to You. To opt-out of receiving these messages, You can use the facility contained in any such communication.

Retention and destruction of Personal Information

We only keep your information for so long as it is necessary to fulfil the purpose for which it was collected and to comply with guidelines for the retention of health records. We will keep your information for a period of 3 years after You or We have closed your Member Account, or if we chose to de-activate the course or if you have not logged into Your Member Account for more than 3 years. After that 3 year period we will delete all of Your information securely in accordance with Our data destruction policies. We may retain some information in anonymised form, for example for statistical analysis and research purposes, but We do no retain any personally identifiable information after the expiry of the 3 year period from the date of closure of Your Member Account or Your last log-in.

Accessing your Personal Information

When Your Member Account is still active (i.e. you have logged-in within the previous 3 years, or your course is still active, You may login to Your Member Account on the Website at any time to view Your Profile Information. If Your Member Account has expired, You may reactivate it by contacting Us at contact@h4c.org.uk. You may update Your email address at any time by logging in and accessing ‘Profile’ settings.

Under the Data Protection Legislation, You have other rights to access, correct and erase Your Personal Information. See the ‘Your Rights’ section below.

Cookies

Cookies are small pieces of information stored by Your browser on Your device’s hard drive. We use cookies to allow Us to track which pages are viewed on the Website, to determine how frequently particular pages are visited, to determine the most popular areas of the Website and generally to monitor usage of the Website. We also use cookies to save a record of access to the courses so We can remind You to complete courses. Most web browsers automatically accept cookies, though You do not have to. If you wish to disable cookies You can do so by readjusting Your browser settings. If You disable cookies You will still be able to use the Website, however You may not be able to use all features of the Website. For more information on cookies and how to disable them, consult the information provided by the Interactive Advertising

Bureau https://www.iab.com/.

For more information on Cookies that We use and on the Third Parties Cookies click here.

Links

This Privacy Policy applies only to Your use of Our Website. Our Website may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

Where we store your data

After initial registration, Your Profile Information and Member Content is stored on secure servers located in the UK.  Your data is protected by encryption in transit and at rest.

Personal Information is initially collected online using a form hosted Qualtrics LLC, a data processor acting on our behalf.  Their servers are in the USA. Our contract with Qualtrics includes standard contractual terms recognised under GDPR to protect personal data. Once We have downloaded data from Qualtrics it is deleted. 

Your rights

We aim to respond to requests from You within two months.

Right to ask us to stop contacting you with direct marketing. Even if You have accepted the processing of Your Personal Information for marketing purposes (by ticking the relevant box), You have the right to ask us to stop processing Your Personal Information for such purposes. See paragraph on ‘Marketing’ above.

Right to request a copy of your information. You can get a copy of your Member Account information and Your Member Content by logging into your Member Account. You can also request a copy of Your information which we hold (this is known as a subject access request). A subject access request may be subject to a reasonable fee to cover the cost of providing you with details of the information we hold about you.  To make a subject access request please contact Us at contact@h4c.org.uk

Right to correct any mistakes in your information. You can require Us to correct any mistakes in Your Member Account information by contacting Us at contact@h4c.org.uk.

Right to request we cease processing your information. You may request that We cease processing your Personal Information. Please contact Us at contact@h4c.org.uk to find out more.

Right to restrict processing of your information. You may ask we restrict processing your Personal Information.  Contact us at contact@h4c.org.uk to restrict our processing Your data. 

Right to request deletion of your information. You can ask Us to erase all Your Personal Information (also known as the “right to be forgotten”). Please contact Us at contact@h4c.org.uk to find out more.

Erasure of Your Personal Information will result in automatic closure of your Member Account and remove your access to the log-in areas of Our Website.

Right to Data Portability. This means that, if you have provided Personal Information to Us directly, We are using it with your consent or for the performance of a contract, and that information is processed using automated means, You can ask Us (at contact@h4c.org.uk) for a copy of that Personal Information to re-use with another service or business in many cases.

Right to object to automated processing. You have a right to object to automated processing of your data. Hope For The Community does not engage in any automated processing.

Complaints

If you have any complaints about the way in which we collect, store and use your information, and these have not been addressed by contacting us first, you can contact the supervisory authority in the United Kingdom, the Information Commissioner’s Office: https://ico.org.uk/concerns/.

Your consent to this privacy policy

By clicking ‘I accept’ during the registration process or by Your continued use of the Website you expressly agree to this Privacy Policy. This is Our entire and exclusive Privacy Policy and it supersedes any earlier version. It should be read in conjunction with the Terms and Conditions and any additional applicable terms posted on the Website.