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Website Privacy Policy

Welcome to Active Prospect’s website privacy policy.

This policy describes how and why Active Prospects uses your personal information, how we protect your privacy when doing so, and your rights and choices regarding this information. We promise to respect any of your personal information which is under our control and to keep it safe. We aim to be clear when we collect your information about what we will do with it.

Data Protection Policy

About this policy

The policy together with the documents referred to within it set out how we comply with our data protection obligations. Its purpose is also to ensure that all staff understand and comply with the rules governing the collection, use and deletion of personal information to which they may have access in the course of their work.
Breaches of this policy may be dealt with under our Disciplinary Procedure and, in serious cases, may be treated as gross misconduct leading to summary dismissal.This policy does not form part of any employee’s contract of employment and it may be amended at any time.

Our Obligations

We are committed to complying with our data protection obligations, and to being concise, clear and transparent about how we obtain and use personal information, and how (and when) we delete that information once it is no longer required. We will comply with the following data protection principles when processing personal information:

• we will process personal information lawfully, fairly and in a transparent manner;
• we will collect personal information for specified, explicit and legitimate purposes only, and will not process it in a way that is incompatible with those legitimate purposes;
• we will only process the personal information that is adequate, relevant and necessary for the relevant purposes;
• we will keep accurate and up to date personal information, and take reasonable steps to ensure that inaccurate personal information are deleted or corrected without delay;
• we will keep personal information for no longer than is necessary for the purposes for which the information is processed; and
• we will take appropriate technical and organisational measures to ensure that personal information are kept secure and protected against unauthorised or unlawful processing, and against accidental loss, destruction or damage.
The Data Privacy Manager is responsible for data protection compliance within the company. If you have any questions or comments about the content of this policy or if you need further information, you should contact the Data Privacy Manager.

Criminal offence information means personal information relating to criminal convictions and offences, allegations, proceedings, and related security measures;
Data breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal information;
Data subject means the individual to whom the personal information relates;
Personal information (sometimes known as personal data) means information relating to an individual who can be identified (directly or indirectly) from that information;
Processing means obtaining, recording, organising, storing, amending, retrieving, disclosing and/or destroying information, or using or doing anything with it;
Pseudonymised means the process by which personal information is processed in such a way that it cannot be used to identify an individual without the use of additional information, which is kept separately and subject to technical and organisational measures to ensure that the personal information cannot be attributed to an identifiable individual;
Sensitive personal information (sometimes known as ‘special categories of personal data’ or ‘sensitive personal data’) means personal information about an individual’s race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (or non-membership), genetics information, biometric information (where used to identify an individual) and information concerning an individual’s health, sex life or sexual orientation.

Basis for processing personal information

In relation to any processing activity we will, before the processing starts for the first time, and then regularly while it continues:
• review the purposes of the particular processing activity, and select the most appropriate lawful basis (or bases) for that processing, i.e.:
* that the data subject has consented to the processing;
* that the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
* that the processing is necessary for compliance with a legal obligation to which we are subject;
* that the processing is necessary for the protection of the vital interests of the data subject or another natural person;
* that the processing is necessary for the performance of a task carried out in the public interest or exercise of official authority; or
* that the processing is necessary for the purposes of our legitimate interests or the legitimate interests of a third party, except where those interests are overridden by the interests of fundamental rights and freedoms of the data subject—see below.
• except where the processing is based on consent, satisfy ourselves that the processing is necessary for the purpose of the relevant lawful basis;
• document our decision as to which lawful basis applies, to help demonstrate our compliance with the data protection principles;
• include information about both the purposes of the processing and the lawful basis for it in our relevant privacy policy/policies or notice(s);
• where sensitive personal information is processed, also identify a lawful special condition for processing that information (see below), and document it; and
• where criminal offence information is processed, also identify a lawful condition for processing that information, and document it.
When determining whether our legitimate interests are the most appropriate basis for lawful processing, we will:
• conduct a legitimate interests assessment (‘LIA’) and keep a record of it, to ensure that we can justify our decision;
• if the LIA identifies a significant privacy impact, consider whether we also need to conduct a data protection impact assessment (‘DPIA’);
• keep the LIA under review, and repeat it if circumstances change; and
• include information about our legitimate interests in our relevant privacy policies or notice(s).
Sensitive personal information

Sensitive personal information is sometimes referred to as ‘special categories of personal data’ or ‘sensitive personal data’.We may from time to time need to process sensitive personal information. We will only process sensitive personal information if:
• we have a lawful basis for doing so as set out above; and
• one of the special conditions for processing sensitive personal information applies, e.g.:
* the data subject has given has given explicit consent;
* the processing is necessary for the purposes of exercising the employment law rights or obligations of us or the data subject;
* the processing is necessary to protect the data subject’s vital interests, and the data subject is physically incapable of giving consent;
* processing relates to personal data which are manifestly made public by the data subject;
* the processing is necessary for the establishment, exercise or defence of legal claims; or
* the processing is necessary for reasons of substantial public interest.
Before processing any sensitive personal information, staff must notify the Data Privacy Manager of the proposed processing, in order that Data Privacy Manager may assess whether the processing complies with the criteria noted above.

Data protection impact assessments (DPIAs)

Where processing is likely to result in a high risk to an individual’s data protection rights (e.g. where we are planning to use a new form of technology), we will, before commencing the processing, carry out a DPIA to assess:
• whether the processing is necessary and proportionate in relation to its purpose;
• the risks to individuals; and
• what measures can be put in place to address those risks and protect personal information.
Before any new form of technology is introduced, the manager responsible should therefore contact the Data Privacy Manager in order that a DPIA can be carried out.

Documentation and records

We will keep written records of processing activities. We will conduct regular reviews of the personal information we process and update our documentation accordingly.

Privacy policies / notices

We will issue privacy policies or notices from time to time, informing data subjects about the personal information that we collect and hold relating to them, how data subjects can expect their personal information to be used and for what purposes. We will take appropriate measures to provide information in privacy policies or notices in a concise, transparent, intelligible and easily accessible form, using clear and plain language.

Individual rights

Data subjects have the following rights in relation to their personal information:
• to be informed about how, why and on what basis that information is processed. This information is set out in our various privacy policies or notices for staff, candidates and clients;
• to obtain confirmation that their information is being processed and to obtain access to it and certain other information, by making a subject access request—see our subject access request policy;
• to have data corrected if it is inaccurate or incomplete;
• to have data erased if it is no longer necessary for the purpose for which it was originally collected/processed, or if there are no overriding legitimate grounds for the processing (this is sometimes known as ‘the right to be forgotten’);
• to object to the processing of personal information.
• to restrict the processing of personal information; and
• to request the transfer of their personal information to another party.
Staff obligations

All staff are responsible for helping us keep their personal information up to date. You should let the HR department know if the information you have provided to us changes, for example if you move house or change details of the bank or building society account to which you are paid.

During the course of your employment or engagement, you may have access to the personal information of other members of staff, candidates, suppliers, customers and clients. If so, we expect you to help us meet our data protection obligations to those individuals.
If you have access to personal information, you must:
• only access the personal information that you have authority to access, and only for authorised purposes;
• only allow other members of our staff to access personal information if they have appropriate authorisation;
• only allow individuals who are not members of our staff to access personal information if you have specific authority to do so from Finance Director and HR Director;
• only process the personal information in accordance with this policy;
• keep personal information secure (e.g. by complying with rules on access to premises, computer access, password protection and secure file storage and destruction and other precautions set out in our systems and data security policy);
• not remove personal information, or devices containing personal information (or which can be used to access it), from our premises unless appropriate security measures are in place (such as pseudonymisation, encryption or password protection) to secure the information and the device and you have consent to do so from Finance Director and IT manager;
• not store personal information on local drives or on personal devices that are used for work purposes.
All staff must read, understand and comply with the provisions of this policy and our other rules, policies and procedures relating to data protection. This includes but is not limited to:
Privacy policies or notices in relation to staff, candidates, PWS, Board members and other third parties;
• Our Website Privacy Policy
• Our Retention Policy;
• Our IT Acceptable Use Policy
• Our IT Security Policy
Our IT Incident Response Policy
Our IT Disaster Recovery Policy
You should contact the Data Privacy Manager if:
• you receive a request from anyone in relation to the individual rights set out above
• you are concerned or suspect that any aspect of this policy has been breached or is likely to be breached.
Information security

We will use appropriate technical and organisational measures to keep personal information secure, and in particular to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage.
Where we use external organisations to process personal information on our behalf, additional security arrangements need to be implemented in contracts with those organisations to safeguard the security of personal information. In particular, contracts with external organisations must provide that:
• the organisation may act only on our written instructions;
• those processing the data are subject to a duty of confidence;
• appropriate measures are taken to ensure the security of processing;
• sub-contractors are only engaged with our prior consent and under a written contract;
• the organisation will assist us in providing subject access and allowing individuals to exercise their rights in relation to data protection;
• the organisation will assist us in meeting our obligations in relation to the security of processing, the notification of data breaches and data protection impact assessments;
• the organisation will delete or return all personal information to us as requested at the end of the contract; and
• the organisation will submit to audits and inspections, provide us with whatever information we need to ensure that we are both meeting our data protection obligations, and tell us immediately if it is asked to do something infringing data protection law.
Before any new agreement involving the processing of personal information by an external organisation is entered into, or an existing agreement is altered, the relevant staff must seek approval of its terms by the Finance Director.

Retention of personal information

Personal information (and sensitive personal information) should not be retained for any longer than necessary. The length of time over which data should be retained will depend upon the circumstances, including the reasons why the personal information was obtained. Staff should follow our retention policy which sets out the relevant retention period, or the criteria that should be used to determine the retention period.
Where there is any uncertainty, staff should consult the Data Privacy Manager.
Personal information (and sensitive personal information) that is no longer required will be deleted permanently from our information systems and any hard copies will be destroyed securely.

International transfers

Actual or possible transfers of personal information outside the European Economic Area (‘EEA’), must only take place if:
• The transfer is clearly set out in the relevant privacy policy; and
• The country in question is either designated as having an adequate level of protection or the organisation has provided adequate safeguards.
Staff dealing with possible transfers of personal information outside of the EEA must ensure the transfer is covered by the relevant privacy policy or notice and should seek guidance from the Data Privacy Manager.

Website Privacy Policy

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected?
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Glossary

1. Important information and who we are

Purpose of this privacy policy
This privacy policy aims to give you information on how Active Prospects collects and processes your personal data through your use of this website, including any data you may provide through this website when you complete our contact form, when you donate to Active Prospects, supply items to ReWorkit, sign up to our newsletter and other marketing materials, or provide services to Active Prospects.

It is important that you read this privacy policy together with any other privacy policy 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 your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. You can find copies of our People we Support Privacy Policy and Board Members on our website and intranet.

Controller
Active Prospects, is a society registered under the Community Benefit Act 2014, registered society number 26618R, with exempt charitable status, and is also a social enterprise. We enable people with learning disabilities, physical and mental health needs to live full and aspiring lives.
Active Prospects is the controller and responsible for your personal data (collectively referred to as “Active Prospects”, “we”, “us” or “our” in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Name: Ian Temple
Email address: info@activeprospects.org.uk
Postal address: 1 Castlefield Court, Church Street, Reigate, RH2 0AH.
Telephone number: 01737 924235
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was last updated in January 2021.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links
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 you. 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.

2. The data we collect about you

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 about you which we have grouped together as follows:

  • Identity Data includes title, first name, last name, date of birth and job title.
  • Contact Data includes address, email address and telephone numbers.
  • Financial Data includes bank account details and Gift Aid details.
  • Donation Data includes details about donations from you and your preference for being contacted by us regarding further donations.
  • Contractor Data includes details of services you have provided to us, references from former clients and details of public liability insurance.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

3. How is your personal data collected?

We use different methods to collect data from and about you including through Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• contact us for general information on our services;
• make a donation;
• supply items to ReWorkit;
• complete a gift aid form;
• sign up for our newsletter, or request other marketing information to be sent to you;
• request to become one of our approved contractors.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.]
• Third parties. We use KindLink to administer donations and manage donor records. If you donate to us KindLink will provide us with personal data relating to you and your donation. A copy of KindLink’s privacy policy is here: https://www.kindlink.com/privacy-policy. KindLink will only provide us with your contact details if you have given consent for them to do so.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the contract we are about to enter into or have entered into with you.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal obligation.
· With your consent.

Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your 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 your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your 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 respond to general queries submitted via our website or otherwise (a) Identity
(b) Contact Performance of a contract with you

To process your donation and submit Gift Aid claims to HMRC
(a) Identity
(b) Contact
(c) Financial (a) Performance of a contract with you
(b) Consent

To send you details on further opportunities to donate to us (a) Identity
(b) Contact
(c) Donation Consent

To process commission payments due to you if you supply items to ReWorkit on a 50/50 profit share basis (a) Identity
(b) Contact
(c) Financial (a) Performance of a contract with you

To add you to our approved contractors list (a) Identity
(b) Contact
(c) Financial Performance of a contract with you

To manage our relationship with you which will include:
(a) Notifying you about changes to specific terms or our privacy policy
(b) Manage payments, fees and charges (a) Identity
(b) Contact
(c) Financial
(d) Contractor
(c) Marketing and Communications (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated)

To administer and protect Active Prospects and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(b) Contact
(c) Technical (a) Necessary for our legitimate interests (for running our charity, provision of administration and IT services, network security, and to prevent fraud)
(b) Necessary to comply with a legal obligation

To deliver our newsletter and other marketing material to you and to keep you updated on the services that we are providing (a) Identity
(b) Contact
(c) Marketing and Communications
Consent
Legitimate interest

To gather feedback from you on our services (a) Identity
(b) Contact (a) Consent
(b) For our legitimate interests (so we can deliver the best service and understand how we can improve our services).

To use data analytics to improve our website, marketing, donor relationships and experiences (a) Technical
(b) Usage Necessary for our legitimate interests (to define types of donors, to keep our website updated and relevant, to develop our charity and to inform our marketing strategy)

Marketing
You will receive marketing communications from us if you have actively signed up to receive a newsletter. You can withdraw your consent to receive our newsletter at any time by following the link to unsubscribe.

Where you opt out of receiving the newsletter, this will not apply to personal data provided to us as a result of a donation, service provision or other transactions.

Cookies
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 this website may become inaccessible or not function properly.

Change of purpose
We will only use your 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 your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

• Service providers acting as processors who provide IT, marketing and system administration services. For example we use MailChimp to manage our marketing communications. A copy of their privacy policy can be found here: https://mailchimp.com/legal/privacy/. We also use SmartSurvey to carry out surveys. A copy of their privacy policy can be found here: https://www.smartsurvey.co.uk/privacy-policy.
• Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK.
• Where we use certain service providers, we may use specific contracts approved by the UK or European Commission which give personal data the same protection it has in Europe and the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your 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 you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?
We will only retain your 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 your 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 you.
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 your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
• Request access to your personal data (commonly known as a “data subject access request”). 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 your personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• 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 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 your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
– If you want us to establish the data’s accuracy.
– Where our use of the data is unlawful but you do not want us to erase it.
– Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
– You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• 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.
• Right to 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

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 your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
What we may need from you
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.
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 your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.