Privacy Policy

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This privacy notice tells you what to expect when What Could Be Ltd collects personal information. It applies to information we collect about:

Visitors to our websites

people who use our services, e.g. who subscribe to our newsletter

Visitors to our websites

When someone visits www.whatcouldbe.com we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. We collect this information in a way which does not identify anyone. We do not make any attempt to find out the identities of those visiting our website (www.whatcouldbe.com). We will not associate any data gathered from this site with any personally identifying information from any source. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

What Could Be Ltd takes your privacy seriously. This privacy policy describes what personal information we collect and how we use it..

Our primary goal in collecting personal information from you is to provide you with a smooth, efficient, and personalised experience while using our services. This allows us to provide services and features that most likely meet your needs, and to customise our service to make your experience easier and quicker. Personal information will be used in accordance with the United Kingdom law and regulation on data protection (in this policy called “Data Protection Requirements”). This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide to us, through this website or otherwise.

This website is not intended for children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 the other notices and is not intended to override them.

1.Data Controller

What Could Be Ltd company number 7710914. Our registered office is at York Mills, York House, Mirfield, West Yorkshire, WF14 9RR. What Could Be is the controller and responsible for your personal data.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below:

Email address: hello@whatcouldbe.com;

Postal address: York Mills, York House, Mirfield, West Yorkshire, WF14 9RR. UK.

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.

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.

2.Your consent

Your use of this website signifies your consent to us collecting and using personal data about you as specified below in accordance with this policy statement. Should we choose to change these terms for any reason, the changes will be posted here so that you are always kept informed about the collection and use of your personal information, and when we disclose it.

3.Data security

3.1.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.

3.2.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.

3.3.We will store all the personal information you provide on our secure password- and firewall-protected servers.

3.4.You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

3.5.You are responsible for keeping your password and other login details confidential. We will not ask you for your password except when you log in to the website. Please do not disclose your login details to anyone else, especially via phone or electronic message.

4.The data we collect about you

4.1.Personal data means any information about an individual from which that person can be identified. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

4.1.1.Identity Data includes first name, maiden name, last name, position, telephone number, email address, username or similar identifier, marital status, title, date of birth and gender;

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

4.1.3.Financial Data includes bank account and payment card details;

4.1.4.Transaction Data includes details about payments to and from you and other details of services you have purchased from us;

4.1.5.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;

4.1.6.Profile Data includes your username and password, purchases or orders made by you, your interests, location, current tools and how you heard about us, preferences, feedback and survey responses;

4.1.7.Usage Data includes information about how you use our website, products and services;

4.1.8.Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences;

4.2.You may require us to process Special Categories of Personal Data about students (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, and information about your health). We will do so on your warranty that you have the authority to control such Special Categories of Personal Data and to pass it to us as processor.

5.How do we collect personal information about you and how is it used?

5.1.We use different methods to collect data from and about you including through:

5.1.1.Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

5.1.1.1.apply for our services;

5.1.1.2.subscribe to our service or publications;

5.1.1.3.request that information about us is sent to you;

5.1.1.4.enter a competition, promotion or survey; or

5.1.1.5.give us some feedback.

5.1.2.Automated technologies or interactions. As you interact with our website, we may 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.

5.1.3.People who call us. When you call What Could Be. we collect Calling Line Identification information. We use this information to help improve its efficiency and effectiveness.

5.1.4.Third parties or publicly available sources. We may receive personal data about you:

5.1.4.1.Technical Data from the following parties based inside or outside the European Economic Area (EEA):

5.1.4.1.1.analytics providers such as Google;

5.1.4.1.2.advertising networks; and

5.1.4.1.3.search information providers;

5.1.4.2.Contact, Financial and Transaction Data from providers of technical, payment and delivery services ;.

5.1.4.3.Identity and Contact Data from data brokers or aggregators;

5.1.4.4.Identity and Contact Data from publicly availably sources.

6.How we use your personal data

6.1.We will only use your personal data when the Data Protection Requirements allows us to. Most commonly, we will use your personal data in the following circumstances:

6.1.1.Where we need to perform the contract we are about to enter into or have entered into with you;

6.1.2.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;

6.1.3.Where we need to comply with a legal or regulatory obligation.

6.2.Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

7.Purposes for which we will use your personal data

7.1.We may to use your personal data to:

7.1.1.enable your use of the services available on the website;

7.1.2.process orders, including sending goods and supplying services, and the management of payments, fees and charges;

7.1.3.manage our relationship with you which will include:

7.1.3.1.notifying you about changes to our terms or privacy policy;

7.1.3.2.improving your browsing experience by personalising the website;

7.1.3.3.sending to you general (non-marketing) commercial communications;

7.1.3.4.sending to you email notifications, sales enquiries, proposals and quotations which you have specifically requested;

7.1.3.5.dealing with enquiries and complaints made by or about you relating to the website;

7.1.3.6.keeping the website secure and to prevent fraud;

7.1.3.7.verifying compliance with the terms and conditions governing the use of the website;

7.1.3.8.inviting you to training, networking and exhibition events we feel may be of interest to you;

7.1.3.9.asking you to leave a review or take a survey;

7.1.4.enable you to partake in a competition or complete a survey;

7.1.5.administer and protect our business and this website;

7.1.6.deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;

7.1.7.use data analytics to improve our website, products/services, marketing, customer relationships and experiences;

7.1.8.make suggestions and recommendations to you about goods or services that may be of interest to you.

7.2.Where you submit personal information for publication on our website, we will publish and otherwise use that information in accordance with the licence you grant to us. Please see our Terms of Service for further details.

7.3.We may provide aggregate statistics about sales, customers, traffic patterns and information to third parties, but these statistics will not include any information that identifies you

7.4.Your privacy settings can be used to limit the publication of your information on the website. You can adjust your privacy settings at any time by emailing us, advising your preferences in detail.

7.5.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.

7.6.Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

7.7.Promotional offers from us

7.7.1.We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

7.7.2.You will receive marketing communications from us if you have requested information from us and have not opted out of receiving that marketing.

7.8.Third-party marketing

7.8.1.We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. If, however, one of our trusted partners has a product or service offering that is of interest, we may contact you to introduce them.

7.8.2.The website contains links to other websites. We are not responsible for the privacy policies or practices of third party websites. We encourage you to read the privacy statements on the other websites you visit.

7.9.Opting out

7.9.1.You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

7.9.2.Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or other transactions.

7.10.Change of purpose

7.11.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.

7.12.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.

7.13.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 the Data Protection Requirements.

8.Disclosure of your personal data

8.1.We may have to share your personal data with

8.1.1.service providers who provide IT and system administration services;

8.1.2.professional advisers;

8.1.3.regulators and other authorities in the United Kingdom who require reporting of processing activities in certain circumstances.

8.2.The personal data disclosed to third parties may:

8.2.1.relate to performance of our contract with you;

8.2.2. be necessary for our legitimate interests or to comply with a legal obligation;

8.2.3.be 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, then the new owners may use your personal data in the same way as set out in this privacy notice.

8.3.We require all third parties to respect the security of your personal data and to treat it in accordance with the Data Protection Requirements. 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.

9.International transfers

9.1.Some of our external third parties may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

9.2.We use a third party provider, Mailchimp, to deliver our occasional e-newsletter. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. For more information, please see Mailchimp’s privacy notice. You will see that personal data is processed by Mailchimp outside of the EEA, and you agree to this.

9.3.Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

9.3.1.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 European Commission (subject to clause 9.2). For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;

9.3.2.where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries; and

9.3.3.where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

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

10.What are cookies and how do we deal with them?

10.1.We use a number of different cookies on our site. If you do not know what cookies are, or how to control or delete them, then we recommend you visit http://www.aboutcookies.org for detailed guidance. The following describes the cookies we use on this site and what we use them for.

10.2.We use both “session” cookies and “persistent” cookies on the website. Session cookies will be deleted from your computer when you close your browser. Persistent cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.

10.3.We will use the session cookies to: keep track of you whilst you navigate the website; keep track of items in your shopping basket; prevent fraud and increase website security; and enhance your user experience. We will use the persistent cookies to: enable our website to recognise you when you visit; keep track of your preferences in relation to your use of our website; and remember your login details.

10.4.The table below explains the cookies we use and why

Cookies Used at What Could Be

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Google Analytics.
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Purpose
These cookies are used to collect information about how visitors use our site, which we use to help improve it. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

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Cookie Alert
ER_CookieAlert

Purpose
This cookie records the fact that a message about cookie use has been shown. It contains no tracking information and expires after 7 days.

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Vimeo cookies
We embed videos from our official Vimeo channel.

Purpose
This means that cookies are set to collect information about how people use this service so that improvements can be made and performance of the service can be monitored.Click here for Vimeo’s privacy policy or click here for their policy on cookies.

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10.5.We do not currently feature advertisers or payment services. However, if we should add these in the future, our advertisers and/or payment services providers may also send you cookies.

10.6.Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

10.7.To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

11.Data retention

11.1.We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

11.2.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 requirements.

11.3.In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.

11.4.In some circumstances we may 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.

12.Your legal rights

12.1.Under certain circumstances, you have rights under Data Protection Requirements in relation to your personal data. Further details are available about these rights from www.ico.org.uk

12.2.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 may refuse to comply with your request in these circumstances.

12.3.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.

12.4.We try to respond to all legitimate requests within one month. Occasionally it may 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.

13.Data Protection Requirements

You have the right to:

13.1.Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

13.2.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.

13.3.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.

13.4.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.

13.5.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 cases:

13.5.1.if you want us to establish the data’s accuracy;

13.5.2.where our use of the data is unlawful but you do not want us to erase it;

13.5.3.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; or

13.5.4.you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

13.6.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.

13.7.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.

Revised 01 May 2019