ATTENDIST LTD – WEBSITE PRIVACY NOTICE
Attendist Ltd respects privacy and is committed to protecting personal data. This privacy notice will inform you as to how we look after personal data when you visit our website (regardless of where you visit it from) and tell individuals about their privacy rights and how the law protects them.
This privacy notice aims to give information on how Attendist Ltd collects and processes personal data through use of, and interaction with, our websites (www.attendist.com and platform.attendist.com), including any data provided through our websites when customers sign up to our service or to receive updates from us.
Our websites are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using personal data.
We are Attendist Ltd, a company registered in England and Wales (Company No. 13768894) with its registered office at Bonded Warehouse, 18 Lower Byrom Street, Manchester, M3 4AP (collectively referred to as “Attendist”, “we”, “us” or “our” in this privacy notice).
Attendist may be either a data controller or a data processor, depending on the circumstances.
We are a “data processor” for the purposes of the Data Protection Act 2018 and the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (“UK GDPR”) whilst conducting our services on behalf of our customers. The customer using our services (or the organisation of which they form part of) will be the “data controller” because it decides whether and when to send any information to us and what we should do with it. Any questions that individuals may have relating to our use of personal information that has been provided to us by a customer and resulting rights under data protection law should therefore be directed to the customer, not to us.
We are a “data controller” in very limited circumstances for the purposes of the Data Protection Act 2018 and the UK GDPR for the information gathered through our use of cookies on our website, for any information gathered as part of registering a new customer of Attendist and for any personal information relating to our own staff and employees.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below.
We keep our privacy notice under regular review. It is important that the personal data we hold is accurate. As independent data controllers, our customers are reminded of their legal obligations to keep us informed of any changes to personal data during their relationships with us, to ensure the information we hold remains accurate and up-to-date.
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 our customers and the information they provide to us. 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.
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 from our customers and other visitors to our websites, which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from personal data but is not considered personal data in law as this data will not directly or indirectly reveal an individual’s identity. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with personal data so that it can directly or indirectly identify individuals, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with our customers, and our customers 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 them (for example, to provide our customers with our services). In this case, we may have to cancel our services, but we will notify our customer(s) if this is the case, at the time.
We use different methods to collect data, including through:
Direct interactions. We may receive Identity, Contact and Financial Data by filling in forms or by through direct correspondence with us by post, phone, email or otherwise. This includes personal data provided when:
Automated technologies or interactions. When interacting with our website, we will automatically collect Technical Data about equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We may also receive personal data from various third parties and public sources as set out below:
Technical Data from the following parties:
Identity and Contact data from social media providers (such as LinkedIn);
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
We will only use personal data when the law allows us to. Most commonly, we will use personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing personal data although we will obtain an individual’s consent before sending third party direct marketing communications via email or text message. Individuals have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use 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.
Note that we may process personal data for more than one lawful ground depending on the specific purpose for which we are using that data. Please contact us if you need details about the specific legal ground we are relying on to process personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register a new customer | (a) Identity | Performance of a contract |
| (b) Contact | ||
| To process and deliver order from customers, including: | (a) Identity | (a) Performance of a contract |
| (a) Manage payments, fees and charges | (b) Contact | (b) Necessary for our legitimate interests (to recover debts due to us) |
| (b) Collect and recover money owed to us | (c) Financial | |
| (d) Transaction | ||
| (e) Marketing and Communications | ||
| To manage our relationship with our customers which will include: | (a) Identity | (a) Performance of a contract with you |
| (a) Notifying customers about changes to our terms and conditions of service or our privacy notice | (b) Contact | (b) Necessary to comply with a legal obligation |
| (b) Asking customers to leave a review or take a survey | (c) Profile | (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| (d) Marketing and Communications | ||
| To enable participation in a prize draw, competition or complete a survey | (a) Identity | (a) Performance of a contract |
| (b) Contact | (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) | |
| (c) Profile | ||
| (d) Usage | ||
| (e) Marketing and Communications | ||
| To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity | (a) 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) |
| (b) Contact | (b) Necessary to comply with a legal obligation | |
| (c) Technical | ||
| To deliver relevant website content and advertisements and measure or understand the effectiveness of the advertising we serve | (a) Identity | 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) |
| (b) Contact | ||
| (c) Profile | ||
| (d) Usage | ||
| (e) Marketing and Communications | ||
| (f) Technical | ||
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | (a) Technical | 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) |
| (b) Usage | ||
| To make suggestions and recommendations to you about goods or services that may be of interest | (a) Identity | Necessary for our legitimate interests (to develop our products/services and grow our business) |
| (b) Contact | ||
| (c) Technical | ||
| ((d) Usage | ||
| (e) Profile | ||
| (f) Marketing and Communications |
We strive to provide choices regarding certain personal data uses, particularly around marketing and advertising.
We may use 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).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
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, warranty registration, service experience or other transactions
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 our websites may become inaccessible or not function properly.
We will only use 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.
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 personal data without knowledge or consent from individuals, in compliance with the above rules, where this is required or permitted by law.
Normally, only our employees will be able to see and process personal data. However, there may be times when we will share relevant information with third parties for the purposes as outlined above, or where we are legally required to do so. When sharing personal information, we will comply with all aspects of data protection law.
Where necessary or required, we may share your personal data as follows:
Our relationships with third party services providers are governed by contractual provisions with us and they only have access to personal information to perform the described purposes and may not use it for other purposes. We require all third parties to respect the security of personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not transfer personal data outside of the UK or European Economic Area. However, there may be some circumstances where it is necessary to transfer and store personal data at a destination outside the UK or the EEA. In these circumstances, we will take all steps reasonably necessary to ensure that personal data is treated securely and in accordance with data protection law and, in the event that personal data is transferred outside the UK or the EEA, shall ensure that this is carried out subject to the requirements of the UK GDPR.
We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify the relevant customer and/or where applicable, the relevant individual and any applicable regulator of a breach where we are legally required to do so.
We will only retain personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain 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 a customer and/or individual.
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 personal data, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances we will anonymise personal data (so that it can no longer be associated with an individual) for research or statistical purposes, in which case we may use this information indefinitely without further notice to the relevant customer and/or individual.
Under certain circumstances, individuals have rights under data protection laws in relation to their personal data.
Individuals have the right to:
Request access to their personal data (commonly known as a “data subject access request”). This enables individuals to receive a copy of the personal data we hold about them and to check that we are lawfully processing it.
Request correction of the personal data that we hold about individuals. This enables them to have any incomplete or inaccurate data we hold about corrected, though we may need to verify the accuracy of the new data provided to us.
Request erasure of personal data. This enables individuals to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Individuals also have the right to ask us to delete or remove their 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.
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.
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:
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.
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.
If a customer and/or individual wishes to exercise any of the rights set out above, please contact the Data Protection Officer, using the contact details set out below.
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 a request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with a request in these circumstances.
What we may need
We may need to request specific information 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if a request is particularly complex or we are dealing with a number of requests for the same individual. In this case, we will notify the individual and keep them updated.
If you have a concern about the way we are collecting or using personal information, we would ask that you raise your concern with us in the first instance by using the contact details below.
You also have a right to lodge a complaint with the Information Commissioner’s Office (ICO) should you feel that we have not handled your information in line with legislative and regulatory requirements. They can be contacted at:
| Postal Address | Telephone Number & Website |
|---|---|
| Information Commissioner’s Office | 0303 123 1113 |
| Wycliffe House | www.ico.org.uk |
| Water Lane | |
| Wilmslow | |
| Cheshire | |
| SK9 5AF |
For further information on how to request your personal information and how and why we process your information, you can contact our Data Protection Officer using the contact details below:
| Postal Address | Email Address |
|---|---|
| Attendist Ltd | info@attendist.com |
| Bonded Warehouse | |
| 18 Lower Byrom Street | |
| Manchester | |
| M3 4AP |
This Privacy Policy is effective as of 2024-02-20 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.
We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.
