Who we are
coliberty.uk is provided by Coalescent (‘We’, ‘Us’, ‘Our’) of C/O Knights, Origin Two, 106 High Street, Crawley, West Sussex, RH10 1BF.
Coalescent is the data controller and responsible for your personal information provided to or gathered by the site.
What this policy does not apply to
What this policy applies to
Where we refer to Data Protection Law below this means;
- unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK, and then
- any successor legislation to the GDPR or the Data Protection Act 2018.
Your privacy is important to us and we will process your data in accordance with Data Protection Law. This says that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
In the event that you believe that there has been a personal data breach, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
Information we hold about you
Personal data, or personal information, means any information that relates to an identified or identifiable individual. It does not include data where the identity has been removed (anonymous data). We will collect, store, and use the following categories of personal information about you:
- Identity data such as first name, last name and organisation.
- Contact data such as addresses, telephone numbers, and email addresses.
If you fail to provide personal information
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How we collect your personal information
You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Sign up to newsletters.
- Sign up to email updates.
- Request demos and other interactive features.
How we use your information
We will only use your personal information when the law allows us to.
To administer and protect our business and site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) we will use your personal information where it is necessary to comply with a legal obligation or for our legitimate interests (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), or those of a third party, but only where your interests and fundamental rights do not override our interests.
To use data analytics to improve our site, services, marketing, customer relationships and experiences where it is necessary to comply with a legal obligation or for our legitimate interests (to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy), but only where your interests and fundamental rights do not override our interests.
To make suggestions and recommendations to you about services that may be of interest to you where it is necessary for our legitimate interests (to develop our products/services and grow our business), but only where your interests and fundamental rights do not override our interests.
We may also use your personal information in the following situations, which are likely to be rare:
- where we need to protect your interests (or someone else’s interests); or
- where it is needed in the public interest.
Situations in which we will use your personal information
We need all the categories of information we keep about you primarily to allow us to use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:
- To provide the relevant service or feature that you have requested.
- To manage your preferences.
- To gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our newsletters and email subscriptions.
- To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
You will have the ability to unsubscribe from any repeat communications at any time.
Change of purpose
We will only use your personal information 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 we need to use your personal information 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 information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law. We may transfer your personal information outside the EU, as set out in “Transferring information outside the EU” below. If we do, you can expect a similar degree of protection in respect of your personal information.
Why might you share my personal information with third parties?
We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
Which third-party service providers process my personal information?
“Third parties” includes third-party service providers (including contractors and designated agents). The following categories of third-party service providers process personal information about you for the following purposes:
- Service providers acting as processors based in the UK who provide IT, development and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- Regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
How secure is my information with third-party service providers?
All our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
What about other third parties?
We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal information with a regulator or to otherwise comply with the law.
Transferring information outside the EU
As our customer relationship software provider (ActiveCampaign) is based in the United States we may have to transfer your personal data out of the EEA. As our provider is part of the Privacy Shield framework it is required to provide your personal data with similar protection as it would receive inside the EEA. See further details here.
We have put in place measures to protect the security of your information. Details of these measures are available upon request.
Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details of these measures may be obtained from our Data Protection Officer.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
We will only retain your personal information 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. 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.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. We will retain and securely destroy your personal information in accordance with our data retention rules that are available on request.
Your legal rights
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.
Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
- 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.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, request that we transfer a copy of your personal information to another party or withdraw consent, please contact our Data Protection Officer in writing via email to the email address set out in the “Contact us or make a complaint” section below.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded, excessive, or you require further copies of the same information. Alternatively, we may refuse to comply with the request in such 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 the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Time limit to respond
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.
We contract with a number of third parties to assist us in providing our site and services. For example, we may use third parties to develop our site and to provide the servers on which our site is hosted. Wherever third parties are involved in processing personal information on our behalf, we shall ensure they do so in accordance with UK Data Protection Law. Third parties are not allowed to use your personal information for their own purposes.
Links to other websites
Contact us or make a complaint
Contact our Data Protection Officer if you:
- think that your personal data has been misused or mishandled
You can contact our Data Protection Officer (DPO):
If these changes affect how your personal data is processed, we will take reasonable steps to let you know.
Last updated: 26 June 2020