1. Introduction
This policy sets out information about the processing of customer data, and how customers’ privacy in relation to their data is protected. This policy does not confer any contractual rights.
A simplified Privacy Notice is set out at Appendix 1.
Recyke y’Bike Ltd. is a registered charity, constituted as a company limited by guarantee. We are registered in the UK as Charity No. 1124639, and Company No. 5839547.
Website: www.recyke.mom
2. Our obligations in relation to processing personal data
- Your data is used lawfully, fairly, and in a transparent way
- Your data is collected only for valid purposes, which have been clearly explained to you
- The data collected is relevant and limited to those purposes
- Your data is accurate and up to date
- Your data is kept only as long as necessary
- Your data is kept securely
3. What data we hold
The data we hold about you is set out in the table at Appendix 2.
4. Why we hold your personal data
Recyke y’Bike is a data controller and needs to collect and hold data about customers in order to undertake the work you have asked us to do.
We are allowed to hold and process data about you because:
- You have consented to our doing so
- We have a legitimate interest in doing so
Recyke y’Bike is registered with the Information Commissioner’s Office (ref. ZA478423).
5. How we collect your data
- Citrus Lime: When you book your bike in for repairs or a service, or when you make a purchase
- Eventbrite: When you sign up for an event
- Mailchimp: When you subscribe to the email newsletter
- Google Forms: Used for volunteer applications
- Embedded content: Articles may include embedded content from third-party websites
- Analytics: We use WordPress.com and Jetpack to measure visitor usage
- Photos and videos: We may take still or moving images with your consent
6. How we use your data
- To respond to your query
- To process applications
- To perform our contract with you
- To remind you about bike servicing
- To keep you informed of special offers
- To update you on our work
- To monitor and evaluate our services
With your consent, we may also use your data:
- To publicise the work of Recyke y’Bike
- To apply for grant funding
- To understand the diversity of our customers
7. How we keep your data
- Accuracy: We take reasonable steps to keep data accurate
- Retention: We follow our Records Retention Policy
- Security: Data is stored securely with limited access
- Deletion: Data is deleted safely and irrecoverably
8. Your rights
- The right to request a copy of your personal data
- The right to correct inaccurate data
- The right to withdraw consent
- The right to data portability
- The right to restrict processing
- The right to lodge a complaint with the ICO
9. Special category data
Recyke y’Bike does not collect special category data from customers.
10. Subject access requests
You are entitled to make a subject access request for copies of any personal data we hold about you.
Requests should be made in writing to the Chief Executive Officer.
11. Data breaches
Where any personal data is lost, destroyed, corrupted or disclosed, this will amount to a data breach.
If a breach occurs, Recyke y’Bike will investigate, contain the breach, assess the risk, and notify the ICO where required.
Date adopted
12 December 2018
Appendix 1: Protecting your data
- We keep your data up to date
- We store it securely
- We do not keep it longer than necessary
- We do not collect it unnecessarily
- We protect it from loss or misuse
- We do not share data without your permission unless required by law
Appendix 2: Table of personal data (customers)
| Information collected | Purpose | Legal basis | Storage | Retention |
|---|---|---|---|---|
| Names, phone numbers, email and postal addresses | Customer contact and order updates | Legitimate interest, consent | Citrus Lime | 6 years from last contact |
| Website visitor analytics | Website performance analysis | Legitimate interest | WordPress.com | Indefinitely (aggregate) |
| Newsletter sign-up details | Marketing and updates | Consent | Mailchimp | Until unsubscribe |
| Photos and videos | Marketing and grant applications | Consent | Google Drive / locked storage | Permanently |
Appendix 3: Consent to photography and filming
I consent to Recyke y’Bike using photographs and/or video recordings including images of me to promote the charity in print and digital media.
I understand images may be viewed worldwide and may be kept permanently as part of Recyke y’Bike’s archive.
Appendix 4: Subject access request form
You are entitled to see most of the information we hold about you. Please contact the Chief Executive Officer to request a copy.