Positive Transition is committed to protecting and respecting your privacy.
Positive Transition is a company established in England whose registered address is Charlotte House, 500 Charlotte Rd, Sheffield, S2 4ER. Our company registration number is 11817348. For the purpose of the General Data Protection Regulation (the “GDPR”), if you use our services, the data controller is Positive Transition Limited. This policy sets out the basis on which we will process any personal data or usage information we collect from you, or that you provide to us, in connection with your use of our websites at *.plus-t.co.uk or our services. Please read this notice carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data. If you do not agree with this Privacy Notice in general or any part of it, you should not access the Website or use our services.
What types of information do we collect and how do we use it?
- Information you give us. You may provide information by signing up for our services, contacting us via our Website, or by email, telephone, social media or otherwise.
- If you use our services through your company, information provided to us by your employer. In the case of our corporate customers only, your employer may provide us with information about you when it signs up to use our services, for example your name and business email address.
- Information provided to us by a third party and/or collected from public records in the case of fraud or suspected fraud. In the case of fraud or suspected fraud, we may obtain information from third parties and from public records to prevent and detect fraud.
To perform our contract with you, we will use your information:
- to communicate with you
- to create records of actions taken in the application
- to provide you with projects to achieve during your internship
- to liaise with your educational body, where applicable
As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our services and organisation, we will use your information:
- to detect and prevent fraud and crime;
- for reporting and data analysis purposes;
- to meet customer service requirements and for complaint handling and feedback;
- to monitor and assess the quality of our service;
- to contact you via telephone, email, or SMS;
- to identify our users;
- to enforce our terms and conditions;
How do we share your personal data?
We do not sell, rent or lease your personal information to others except as described in this Privacy Notice. We share your information with selected recipients. These categories of recipients include:
- cloud storage providers located in the UK to store the personal data you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you;
- provided you have consented, advertisers and e-marketing companies located in the UK and which store your personal data in the UK that require the data to select and serve relevant marketing and adverts to you and others;
- IT support service providers who support and maintain our applications and have secure access to our servers
We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
- comply with a legal obligation, process or request;
- enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
- detect, prevent or otherwise address security, fraud or technical issues; or
- protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
We will also disclose your information to third parties:
- in the event that we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets; or
- if we or substantially all of our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.
Where do we store your personal data?
For administrative reasons data may be passed to and stored securely with third party service providers located outside the UK. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this policy.
The security of your personal data
Depending on the transmission environment and methods used by the user, we cannot ensure that data submitted by the user is secure and therefore at the user’s risk. Once we have received your information, we will take appropriate technical and organisational measures to safeguard your personal data against loss, theft and unauthorised use, access or modification. Data held will be monitored and controlled under supervision. We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.
How long do we store your personal data?
To determine the retention period of your personal data, we consider several criteria to make sure that we do not keep your personal data for longer than is necessary or appropriate. These criteria include:
- the purpose for which we hold your personal data;
- our legal and regulatory obligations in relation to that personal data, for example any financial reporting obligations;
- whether our relationship with you is ongoing, for example, you have an active account with one or more of our brands, you continue to receive marketing communications, or you regularly browse or purchase off our Website);
- whether you are no longer actively participating or engaging with our brands, for example, you do not open our emails, visit our Website, or share user generated content;
- any specific requests from you in relation to the deletion of your personal data; and
- our legitimate business interests in relation to managing our own rights, for example the defence of any claims.
We will retain your information as follows:
- your user profile and account information (including your technical usage data), for 6 years after you last use our services;
- if you contact us via email we will keep your data for 5 years;
- records of orders and complaints for a minimum of 12 months.
After you have terminated your use of our services, we will store your information in an aggregated and anonymised format.
You have rights in relation to the personal data we hold about you. Some of these only apply in certain circumstances. We have described these situations below, as well as how you can exercise your rights. To exercise any of your rights, please contact us at email@example.com
- Access: You have the right to ask us to access the personal data we hold about you and be provided with certain information about how we use your personal data and who we share it with.
- Correction: You also have the right to ask us to correct your personal data where it is inaccurate or incomplete.
- Portability: Where you have provided your personal data to us under contract, you have the right to ask us to share (port) this data to another data controller in a structured, commonly used and machine-readable format.
- Erasure: In certain circumstances, you have the right to ask us to delete the personal data we hold about you.
- Restriction: In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal data, save for storage.
- Objection: In certain circumstances, the right to restrict or object to our processing of your personal information (e.g. where you request correction or erasure, you also have a right to restrict processing of your applicable data while your request is considered). You can object to our processing of your personal data based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.
In addition, you have the right to complain to the Information Commissioner’s Office or other applicable data protection supervisory authority
Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or company trade secrets or intellectual property, where there are overriding public interest reasons or where we are required by law to retain your personal data.
Objection to Marketing
At any time, you have the right to object to our processing of data about you in order to send you marketing communications, including where we build profiles for such purposes, and we will stop processing the data for that purpose.
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at firstname.lastname@example.org and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the Information Commissioner’s Office or the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.