We care about your privacy and are committed to protecting your personal data. Here are our promises to you:
- To only collect personal information from you when it improves your experience of our platform.
- To ask for and record your consent for collecting personal information.
- To never sell your personal information to third parties.
- To explain why we are asking for personal information when we ask for it (unless it is obvious).
- To protect your data and store it safely.
- To respect your wishes and rights in regard to our storage of your data.
Our address is:
School House Office,
Market Street, Devoran,
You can contact us by emailing firstname.lastname@example.org or phoning us on +44 (0)1872 862547.
We are a limited company registered in England and Wales (our registration number is 4309700). We are also registered with the Information Commissioner’s Office for data protection purposes (our registration number is Z2818556).
All data captured via our platform is securely stored with our internet hosting provider Cloud Above Ltd, of:
1 King Mark House,
Made Open have licenced this platform to Torbay Community Development Trust Ltd of:
4 - 8 Temperance Street,
Torbay Community Development Trust are delivering this service to you under the name of Torbay Together.
All the personal data we collect is outlined in the table below:
|Data type||What this means|
|Location data||Your neighbourhood or region (optional)|
|Marketing data||Your public profile (optional)|
|Activity data||Activity information (automatic)|
|Exchange data||Additional data required to join the timebank (mandatory)|
We also collect, use and share “aggregated data” such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but it will not constitute personal data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity.
No special categories of personal data
We do not collect any “special categories of personal data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We will only use your personal data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
What is our “legal basis” for processing your personal data?
The General Data Protection Regulation (GDPR) requires us to ensure that we have a legal basis for using your personal data. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests (“Legitimate Interests”). More detail about the specific legitimate interests we use your personal data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the purpose in question (“Consent”).
Generally, we do not rely on your consent as a legal basis for using your personal data (other than in the context of direct marketing communications).
We have set out below, in a table format, the legal bases we rely on in respect of the relevant purposes for which we use your personal data:
|Purpose||Categories of personal data involved||Why do we do this||Our legal basis for this use of data|
|Registering an account||
Identity and contact data:
|Setting up your profile||
Identity and marketing data:
|To raise your profile to other users of the platform.||Legitimate interest|
|Setting up your Best Match||
To quickly match you to relatable activities and members using the ‘Best Match’ button.To allow you to share some or all of your location, skills and interests onto your public profile.
Activity and contact data:
To describe your activity in more detail and enable other members or a platform administrator to contact you.
|To let you manage your connections.||Legitimate interest|
|Joining the exchange||
|To help the platform administrator determine whether you are eligible to join the exchange.||Legitimate interest|
Identity, contact, behavioural and marketing data:
Your information will be used for the purposes described. Third parties will only receive personal information about you when you have consented or when protecting our legitimate business interest. Scenario’s where we may disclose your personal information include:
- When sharing it with our employees to improve the platform’s user experience.
- When required to do so by law.
- In the event that we sell our business or business assets.
- In order to establish, exercise or defend our legal rights.
- To protect the rights, property or safety of Made Open, our clients, or others.
Except as described, we will not provide or sell your personal information to third parties.
The table below describes who we share your personal data with (including ourselves), what we share and why we share it. We do not and will not transfer your personal data to any parties located outside the European Economic Area.
|Who we share data with||What we share||Why we share it|
|Made Open Communications Ltd||
For the purposes of the General Data Protection Regulation (GDPR) and Data Protection Act 1998, the data controller responsible for collecting information is Made Open.
Made Open Communications Ltd
Made Open have licenced this platform to Made Open Communications Ltd.
This personal data enables associates of Made Open Communications Ltd to perform their duties as platform administrators.
|Cloud Above Ltd||Technical data||
All data captured via our software service is securely stored with our internet hosting provider Cloud Above Ltd.
We respect people’s data and take care to ensure that your personal data is stored safely and securely. We store all your personal information on our secure UK based servers, which:
- Use strong password protection.
- Have regular security patches and system updates.
- Have an industry standard Firewall policy.
- Use authentication.
- Apply user auditing.
We have industry recognised security measures in place to prevent our platform from being hacked including: password hashing and salting, SQL injection projection techniques applied to all data input forms, regular updates and security reviews.
Transmitting information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the site. Any transmission is at your own risk.
You are responsible for keeping your password and user details confidential. We will not ask you for your password (except when you log in). We ask you not to share your password with anyone.
We will only retain your personal data until either of the following happens (or unless a longer retention period is required by law):
- You decide to delete your account.
- You wish to enact your right to be forgotten.
- The website is terminated.
By law you have the right to:
- Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
- Object to processing of your personal data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you; for example, if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal data. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 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. This right only exists where we are relying on consent to process your personal data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our platform. We will advise you if this is the case at the time you withdraw your consent.
Our policy on children
This platform is not intended for children below 16 and we do not knowingly collect data relating to such children.
Personal data from third parties
This platform does not currently collect any personal data from third parties. For members joining our exchange, our administrators may reference check you from third party sources. This will only be done with your permission, using the references you have provided. This is to protect your and our legitimate interests - allowing you to make exchanges freely once authorised, and allowing our administrators to provide an extra safeguarding check for the benefit of all our members.
What happens if we need more personal data?
Where we need to process your personal data either to comply with the law, or to meet the terms and conditions of use we have with you, and you fail to provide that data when requested, we may have to stop you using our platform. We will notify you if this is the case at the time.
This platform does not and will not send out any marketing messages from third parties. You can ask us to stop sending you marketing messages at any time by signing into the platform and checking or unchecking relevant boxes to adjust your marketing preferences and / or by following the opt-out links on any marketing messages sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of use of our platform.
If you want to exercise any of the rights described above, please contact us by emailing email@example.com or phoning us on +44 (0)1872 862547.
Typically, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you 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.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.