PRIVACY POLICY

Last updated: April 2024

This privacy notice sets out how we as a company use and protect any personal data that you give both when you use our website or that is gathered during the course of operating our business. Our priority is to ensure that your privacy is protected.

About us

Shape History Limited is a company registered in England and Wales with company number 9491473. Our data protection registration is ZA757573.

If you have any questions or concerns about the information in this notice or would like any further information regarding our handling of personal data, please contact Lauren Kay-Lambert: lauren@shapehistory.com or write to Shape History, 77 Fortess Road, London, England, NW5 1AG.

Alternatively fill out our web form.

Important information

Our website is not intended for children and we do not knowingly collect data relating to children via our website. However in some circumstances we do record visual images of children and how we do so and the protections in place are described below.

It is important that you read this privacy notice 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 notice supplements other notices and privacy policies and is not intended to override them.

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.

Our website

Our 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 or notice of every website you visit.

Types of personal data

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 first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and the services we have provided to you.

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 and services we provide.

Marketing Data includes your preferences in receiving marketing from us and our third parties 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.

Personal data may include ‘special categories of data’ (previously referred to as ‘sensitive data’). Special categories of personal data are defined by the General Data Protection Regulation 2018 (GDPR) and the UK Data Protection Act 2018 (DPA) as including any of the following types of information about an identifiable, living individual:

racial or ethnic origin
political opinions
religious beliefs
trade union membership
physical or mental health
sexual life or sexual orientation
commission of offences or alleged offences
genetic data
biometric data

Please see below for more information on our processing of special categories of personal data.

Personal data we collect about you and how we use it

Personal data is collected in several different ways depending on your interaction with Shape History. The purposes for processing your personal data are outlined in the table below. More information is provided below the table about how we collect and use 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.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before processing any special category personal data or prior to your participation in research.

Purpose/Activity	Type of data (see above for explanation)	Lawful basis for processing including basis of legitimate interest
To register you as a new partner	(a) Identity (b) Contact	Performance of a contract with you.
To provide our services to partners including: – Manage payments, fees and charges – Collect and recover money owed to us	(a) Identity (b) Contact (c)Financial (d)Transaction (e) Marketing	Performance of a contract with you. Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include notifying you about changes to our terms or privacy notice	(a) Identity (b) Contact (c) Marketing	Performance of a contract with youNecessary to comply with a legal obligation. Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	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). Necessary to comply with a legal obligation.
To use data analytics to improve our website	(a)Technical (b) Usage	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)
To carry out research	Identity	Performance of a contract with you. Necessary for our legitimate interests (to provide our services to partners)

Website visitors and enquiries

We collect personal data directly from website visitors or users through the use of online forms as well as when you submit an online enquiry.

We also collect information automatically about your visit to our website. 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. Further information about ‘Cookies’ is set out in our Cookies Policy.

Accounts and records

the administration of partner accounts and payments
the collection of payment
to maintain a records of customers
to enable us to fulfil statutory reporting obligations
to contact individuals who have provided disability details at the point of application or upon joining us as staff or visitor with regard to arrangement of reasonable adjustments
to carry out staff discipline and misconduct processes
to administer the academic appeals process

Research

Throughout the course of the research carried out under the course of our services, personal data may be gathered.

Research participants will be provided with an information sheet relating to the specific piece of research they are participating in, as well any consent form(s) we may rely on to ensure transparency and clarity regarding data collection, use, and retention.

Vital interests

We may also process your personal data because it is necessary to protect you or another person’s vital interests, for example in a life-or-death situation where urgent medical help is required.

Image capture

As part of our legitimate interest in operating our business, we may provide images of an individual to our Partners as part of the research findings or other projects we are working on, on their behalf. Permission to use and re-use images or footage must be provided to us by way of a form granting us permission to use and re-use images. In addition our form provides confirmation that we have consent from the subject of the image for third parties to use the image as proposed.

If we capture an image of a person aged under sixteen years we will rely on the consent granted by the consent of the child’s parent or legal guardian. If a young person is sixteen or seventeen and deemed able to understand the concept of consent they can grant consent themselves.

Retention of personal data

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. Our document retention policies are available on request.

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.

Disclosure and transfer of personal data

We will only disclose your personal data to a third party when we are required to by law, where we have your specific consent, or where appropriate arrangements are in place with regard to data sharing – for instance:

companies or suppliers with whom we engage to process data on our behalf – if so, we will ensure adequate arrangements are in place to protect your personal data, such as a Data Sharing Agreement and third-party security review
third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business or is proposed to happen, then the new owners may use your personal data in the same way as set out in this Privacy Notice.
professional and regulatory bodies in relation to confirmation of qualifications, professional conduct, and the accreditation of courses
legal representatives
internal and external auditors.
Government departments and agencies

From time to time, Shape History will transfer limited personal data outside the European Economic Area. After the United Kingdom has officially left the European Union in January 2021, Shape History will adhere to the requirements of data protection legislation subject to the status of UK data protection legislation and EU legal requirements.

Where personal data is transferred outside of the EEA, Shape History will ensure that standard contractual clauses are in place where there is no adequacy decision in place to cover the transfer and that adequate technical and organisational controls are in place. The Company ensures that appropriate agreements with regard to data sharing are in place with contracted service providers and international institutions outside the EU.

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.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, 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.

Your Legal Rights

You have the right to:

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 the 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 of 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.

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.

Glossary

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.

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PRIVACY POLICY