Before we begin
We are committed to protecting your privacy, and we take our responsibilities regarding the security of user information very seriously. This policy explains how we use your information and how we protect your privacy.
Please read this policy carefully, as we will ask you to give your express agreement to it and consent to the terms of it for data protection purposes (for example, by ticking the appropriate box on our website).
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Introduction
In this policy, "we", "us" and "our" refer to ACTIONSTORM LTD (Company number: 11605171) with registered office at Office F3, The Old Church, 89b Quicks Road, London, England, SW19 1EX.
by post, to any address on our website;
by email, using the email address published on our website at ActionStorm.org from time to time.
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Amendments
We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
We may notify you of any significant changes to this policy by email or using any other contact details we hold for you.
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How we use your personal data
In this Section 3 we have set out:
the general categories of personal data that we may process;
the purposes for which we may process personal data; and
the legal bases of the processing.
We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services.
We may process your account and personal data (“personal data”). The personal data may include any data you provide to us on signup, including but not limited to your name, email address, petition description, your organisation, any comments and any information about the types of support a user states that they can provide to a person creating a petition. The personal data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
We may process information contained in any enquiry you submit to us regarding our services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing will be consent.
We may process information relating to transactions, including purchases of memberships or service packages, which you enter into with us and/or through our website (“transaction data”). The transaction data may be processed for the purpose of supplying those services and keeping proper records of those transactions.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
We may process any of your personal data identified in this policy, for the following reasons, which provide the legal basis for the processing:
where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice - the legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks;
the proper administration of our website and business, and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject.
We may also collect and process any of your personal data, gathered via any of the following specific ways:
during the user signup process or any other method of communication between us;
data exchanged between end users (those viewing and signing up to petitions) via any means, including any chat system, message board or other peer-to-peer communication system on our website;
data exchanged between creators of petitions and end users on our website.
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Providing your personal data to others
We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
We may disclose your personal data to our insurers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure, or for any other legitimate purpose.
Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
Personal data may also be disclosed by us to the person, entity or organisation who created a petition and which you signed up to, provided that you ticked the box or other similar method stating that you would like to see updates about that petition, or any similar wording.
Should you choose to share a petition with third party entities, such as social media providers, we cannot control how those third party entities process or disclose any personal data which may be identifiable by you choosing to share a campaign and we shall have no liability or obligation to you in relation to the same.
Once any personal data has been provided to a third party by us and with your consent given herein, we have no control over that data, how it is processed or disclosed, and we shall have no liability or obligation to you in relation to the same.
Although we do our best to keep your data secure, third parties such as hackers may obtain access to your personal and other data (including whether you have signed up to a particular petition) by illegitimate means and we shall have no liability or obligation to you in relation to the same.
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Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data whilst we have a contract with you (and for six years thereafter to meet any possible legal requirements); and indefinitely for the purposes of marketing.
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on how long we consider it is reasonable to retain such data for the purposes specified in Section 3.
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Your rights
In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included. Please seek legal advice, should you wish to know more.
Your principal rights under data protection law are:
the right to access;
the right to rectification;
the right to erasure;
the right to restrict processing;
the right to object to processing;
the right to data portability;
the right to complain to a supervisory authority; and
the right to withdraw consent.
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure.
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent, or for other legal reasons.
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
To the extent that the legal basis for our processing of your personal data is:
consent; or
that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us.
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About cookies
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
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Cookies that we use
We may use cookies for the following purposes:
authentication - to identify you when you visit our website and as you navigate our website;
personalisation - to store information about your preferences and to personalise the website for you;
security - as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally;
advertising - to help us to display advertisements that will be relevant to you;
analysis - to help us to analyse the use and performance of our website and services; and
cookie consent - to store your preferences in relation to the use of cookies more generally.
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Cookies used by our service providers
Our service providers use cookies and those cookies may be stored on your computer when you visit our website – such as Google Analytics and Google AdSense advertisements.
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Managing cookies
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via searching about your specific browser using an internet search engine.
Blocking all or some cookies may have a negative impact upon the usability of many websites, and you may not be able to use all the features on our website.