Wishing you a merry Christmas and a happy New Year!
Wishing you a merry Christmas and a happy New Year!
ATFOA Privacy Policy
[UPDATED: January 2, 2024]
We respect the privacy of every person who visits https://atfoa.co.uk (the “Website”) and who uses the services that we provide and/or promote on our Website (our “Services”) and we are committed to ensuring a safe online experience.
1. Purpose of this Policy.
This privacy policy (“Privacy Policy”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third-party and the purposes for which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information.
This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.
This Privacy Policy is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it.
Please also note that this Privacy Policy only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties.
Finally, our Website may use certain web beacons, pixel tags, log files and other technologies.
2. Who are we?
The Website and our Services are operated by ATFOA (“we”, “us” or “our”). ATFOA is a trade association. ATFOA is the data controller responsible for your personal information.
3. How to contact us?
If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by sending an email to atfoa@atfoa.co.uk.
4. What personal information do we collect and how do we use it?
Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us deliver our Services; (iii) help us improve the Services and develop and market new services; (iv) send you marketing and communications; (v) carry out requests made by you on the Website; (vi) investigate or settle inquiries or disputes; (vii) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (viii) enforce our agreements with you; (ix) protect the rights, property or safety of us or third parties, including our other customers and users of the Website; (x) provide support for the provision of our Services; (xi) recruitment purposes; (xii) facilitate payments; and (xii) use as otherwise required or permitted by law.
In particular, we use your personal information for the following purposes:
A. Fulfilment of Services.
We collect and maintain personal information that you voluntarily submit to us during your use of the Website and/or as part of us providing our Services to you. We use the information that you have provided to us so that we can fulfil the supply of Services you have engaged us to provide.
Who do we share your personal information with for this purpose?
We may share, where relevant, your personal information (e.g. name, contact information including email address, professional information and other information relevant to the provision of our Services, or any personal information that you provide to us as part of our providing the Services) with third parties. These include:
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you.
B. Your feedback about Services.
From time to time we will ask you to provide feedback about our Services in the form of a survey. We use this information to help us improve the quality of service provided by us. We also use your feedback to monitor the quality of our Services.
Who do we share your personal information with for these purposes?
We share your information with a third-party customer survey company who assists us with administering the surveys and you will receive a voluntary request to participate.
What is our legal basis?
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.
C. Insight and analysis.
We analyse your contact details with other personal information that we observe about you from your interactions with our Website, with our email communications to you and with our Services.
Where you have given your consent (where lawfully required), we use log files and other technologies to collect personal information from the computer hardware and software you use to access the Website, or from your mobile device. This includes the following:
Our Website and emails may contain web beacons and pixel tags (“Tags”). Tags allow us to track receipt of an email to you, count users who have visited a web page or opened an email and collect other types of aggregated information. Once you click on an email that contains a Tag, your contact information may subsequently be cross-referenced to the source email and/or the relevant Tag.
In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.
This information is used to create insights about our visitors’ browsing habits on our Website. Where we have your consent to do so, we will also use your location data for insight and analysis purposes.
By using this information, we are able to measure the effectiveness of our content and how visitors use our Website and our Services. This allows us to learn what pages of our Website are most attractive to our visitors, which parts of our Website are the most interesting and what kind of features and functionalities our visitors and clients like to see. We also use this information to help us with the selection of future service lines and website design and to remember your preferences.
We may also use this information for marketing purposes (see the ‘Email marketing’ section below for further details).
Who do we share your personal information with for these purposes?
We may share your personal information with a variety of third-party service providers to assist us with customer insight analytics.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide good quality products and services to you and our other visitors and clients.
We will only use your location data for insight and analysis purposes where we have your consent to do so.
D. Email marketing.
We may use information that we observe about you from your interactions with our Website, our email communications to you and/or with our Services (see the ‘Insight and Analysis’ section above for more details of the information collected and how it is collected) and/or your name and email address, to send you marketing communications by email, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.
Who do we share your personal information with for these purposes?
We may share your personal information with third-party email marketing providers who assist us in delivering our email marketing campaigns to you.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes. We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so.
E. Business administration and legal compliance.
We use your personal information for the following business administration and legal compliance purposes:
Who do we share your personal information with for these purposes?
We will share your personal information with professional advisers such as IT support providers, lawyers and accountants and/or governmental or regulatory authorities.
What is our legal basis?
Where we use your personal information in connection with IT support, to obtain legal advice and/or enforce our legal rights, to protect the rights of third parties or as part of a business transition, it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
Where we share your sensitive personal information, we shall obtain your consent to do so.
F. Recruitment.
We may use your personal information (e.g. name, job title, contact information including email address, curriculum vitae, your education, employment history and similar matters and similar information that you may provide to us and any other information relevant to potential recruitment) for the following recruitment purposes:
Who do we share your personal information with for these purposes?
We will share your personal information with external recruiters where we have engaged them to find a candidate for a specific role at ATFOA.
What is our legal basis?
Where we use your personal information in connection with recruitment it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions for ATFOA. We will not process any special data except where we are able to do so under applicable legislation or with your explicit consent which shall be obtained at the time we collect your personal information following the instructions provided.
G. Other.
Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.
5. How do we obtain your consent?
Where our use of your personal information requires your consent, you can provide such consent:
6. Third-Party Links and Services.
Our Website contains links to third-party websites and services. Please remember that when you use a link to go from our Website to another website or you request a service from a third-party, this Privacy Policy no longer applies.
Your browsing and interaction on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies and you should contact the appropriate third-party if you have any questions. We do not monitor, control, or endorse the privacy practices of any third parties.
7. Transfers outside the EEA.
Where necessary in order to deliver our Services, we will transfer personal information to countries outside the EEA. When doing so, we will comply with our legal and regulatory obligations in relation to the personal information including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.
8. How long do we keep your personal information for?
We do not keep your personal information for any specific period but will not keep it for longer than is necessary for our purposes. In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations.
9. Confidentiality and security of your personal information.
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.
10. How to access your information and your other rights?
You have the following rights in relation to the personal information we hold about you:
A. Your right of access.
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
B. Your right to rectification.
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
C. Your right to erasure.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
D. Your right to restrict processing.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
E. Your right to data portability.
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third-party of your choice.
F. Your right to object.
You can ask us to stop processing your personal information, and we will do so, if we are:
G. Your rights in relation to automated decision-making and profiling.
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
H. Your right to withdraw consent.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
I. Your right to lodge a complaint with the supervisory authority.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns or by calling their helpline on 0303 123 1113.
11. Changes to this Privacy Policy.
We may make changes to this Privacy Policy from time to time.
To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by email of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.
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