ROKT Foundation understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.roktfoundation.co.uk (“Our Site”), and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
- Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site;
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”);
means any person who publishes information on publicly available websites;
means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and
ROKT Foundation (“We”). We are registered at the Charity Commission under Charity Number 1175904
- Information About Us
2.1 Our Site is owned and operated by ROKT Foundation (“We”). We are registered at the Charity Commission under Charity Number 1175904
2.2 Our Data Protection Officer is M E NOBLE, and can be contacted by email at email@example.com
- What Does This Policy Cover?
- Your Rights
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office, at www.ico.org.uk/concerns.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
- What Data Do We Collect?
5.2 business/company name
5.3 job title;
5.5 contact information such as email addresses and telephone numbers;
5.6 demographic information such as post code, preferences, and interests;
5.7 web browser type and version;
We also crawl and index publicly available information (including data) from the Internet. We also contract directly with third party providers to gain access to their information (including data). In each case, the information that we have access to is published or made available by Creators. This information is then collated and stored in our database. We offer access to our database, as well as analytics of the data within that database, to third parties (our “Services”).
Since all of the information that we access is publicly available, the raw information we have about you could be found by anybody with access to the Internet. Some of this information is personal data. For example your name or username in connection with your Twitter or Facebook profile would be personal data. Other information we process may not be personal data (for example if you publish an anonymous review on a website).
As Creator, you are the source of the data. You have control over that data within the platform you choose to publish it on, including through using the privacy settings made available to you by that platform. In addition to whatever rights you have via your relationship with any publishing platform, you also have certain rights relating to your data that we process, as set out in this Privacy Statement.
The data we collate from Creators depends upon the source of the data, what the source or platform chooses to make available to us, plus what a Creator chooses to make available. It could include the following:
5.8 Name, username, handle or other identifier;
5.9 The content of the information you have published via that name, username, handle, or other identifier, including comments, expressions, opinions, posts, etc.;
5.10 Your profile picture or other images or videos that you post or interact with;
5.11 Your job title or profession (including category of profession, for example “journalist”;
5.12 Your interests;
5.13 Your location;
5.14 Your gender; and
5.15 Any other information you publish on an Internet website we crawl or on a third party platform that provides us with data.
We may also analyse the content of the data you publish and provide our analysis to our customers. For example, if you publish a Tweet stating that you like a certain brand’s ice cream, we may mark that Tweet as having a positive sentiment toward that brand.
- How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use the data identified in Clauses 5.1 to 5.7 for the following purposes:
6.2.1 Providing and managing your Account;
6.2.2 Providing and managing your access to Our Site;
6.2.3 Personalising and tailoring your experience on Our Site;
6.2.4 Supplying our services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.5 Replying to emails from you;
6.2.6 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.
6.3 The legal basis for the processing of the data identified in Clauses 5.8 to 5.15 is pursuant to our legitimate interests. Our legitimate interests are in providing our Services to our customers, which includes providing technology that empowers our customers to act with more certainty in a way that is easy-to-access and use. In turn, this allows our customers to learn more about their brand, their markets, their competitors, and other information available on the social web that is relevant to our customers.
6.4 We also use the data in ways related to, but ancillary, to the Services that we offer. For example, we may use the data to comply with our legal obligations or enforce our rights, including the legal obligations or enforcement of rights of third parties. We may also use the data to improve our Services.
6.5 Although it is the responsibility of our customers to use our Services properly, we do put in place safeguards to protect your data. We require our customers to comply with applicable law, including data privacy law, when using our Services. We also prohibit our customers from using our Services, including your data, in a way that is outside of your reasonable expectations.
6.6 When we infer data about you, we do so automatically. The inferences are based on algorithms that analyse the data that you have posted. We do not make any decisions about you based on the data that we process about you (inferred or not). In other words, we only make the data available to our customers. It is up to our customers what (if anything) to do with the data and any inferences about the data
6.7 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.7.1 Data identified in Clauses 5.1 to 5.7 for a period of 6 years, in accordance with the Limitation Act 1980;
6.7.2 Data identified in Clauses 5.8 to 5.15 will be retained for as long as it is reasonably necessary for us to provide the Services.
However, if you request that we delete your data, or if you delete your data from the platform in which it was originally published, we will also delete your data from our Services.
- How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 We may transfer your data to, and store it in, a country other than your own. That country may not provide the same level of data protection as your own country. Whenever we transfer your information outside of Europe, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely. If you are located in Europe, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.
7.3 The servers in which we hold your data have appropriate administrative, technical, and physical controls that are designed to safeguard your data, including industry-standard encryption technology.
- Do We Share Your Data?
8.1 In addition to sharing the data identified in Clauses 5.8 to 5.15 with our customers, in certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
8.2 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
- What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
- How Can You Control Your Data?
10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- Your Right to Withhold Information
- How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at firstname.lastname@example.org, or using the contact details below in section 13.
- Contacting Us