Effective date: May 25, 2018

  1. WHO ARE WE?

This website (https://cultivatelondon.org) is operated by Cultivate London Limited, a company registered in England and Wales under registration number 7474198 and a charity registered in England and Walesunder registration number 1147015(“Cultivate London”, “CL”,“we”“us” and/or “our”). Our registered address is; Cultivate London Plant Nursery, Enfield Road, Acton, London W3 8RA. You can contact us as indicated under the “Contact” section below.

The data controller responsible for your personal data is the Cultivate London company (“Cultivate London”, “CL”, “we”“us” and/or “our”).

Our Data Protection Officer is Olivia Rigg, for all data matters contact her at data@cultivatelondon.org

  1. WHAT IS THIS PRIVACY POLICY IS FOR?

This privacy policy (“Privacy Policy”) informs you (“you” or “your” being interpreted accordingly) of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

It provides information on what personal data we collect, why we collect the personal data, how it is used and the lawful basis on which your personal data is processed, and what your rights are under the applicable data protection and privacy laws, including the General Data Protection Regulation (“GDPR”) which will become applicable to us and you as of 25 May 2018.

By using our Service or submitting your personal data you are taken to accept the terms of this Privacy Policy, so please read it carefully.

  1. DEFINITIONS

Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies
Cookies are small pieces of data stored on a User’s device.

Data Controller
Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your data.

Data Processor (or Service Providers)
Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.

Data Subject
Data Subject is any living individual who is the subject of Personal Data.

User
The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

  1. INFORMATION WE COLLECT

We collect several different types of information for various purposes to provide and improve our Service to you.

Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). You may choose to provide Personal Data when corresponding with us by phone or e-mail, participating in user/customer surveys, otherwise visiting and interacting with this Service and visiting one of our gardens or other premises.

Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  1. AUTOMATICALLY COLLECTED PERSONAL DATA

Usage Data
We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and hold certain information. View cookies policy.

  1. HOW WE USE YOUR PERSONAL DATA

We use your personal data for various purposes in the following ways:

  • To provide and maintain our Service.
  • To notify you about changes to our Service.
  • To allow you to participate in interactive features of our Service when you choose to do so.
  • To contact you in connection with user/customer surveys and use any information you choose to submit in response, provided that you gave us your consent to being contacted in this way at the time you provided us with the personal data.
  • Cultivate London may provide you with information about services, events and other promotions we feel may interest you as a user of our Service. We will contact you by email only with your consent, which was given at the time you provided us with the personal data.
  • As necessary for certain legitimate business interests, which include the following:
    • to provide customer support
    • where we are asked to deal with any enquiries or complaints you make
    • to gather valuable information and conduct analytics to inform our marketing strategy and so that we can improve our Service
    • to administer and monitor the usage of our Service to better understand how visitors interact with our website and ensure that it is presented in the most effective manner for you and for your computer/device
    • To detect, prevent and address technical issues for internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our website, network and information systems secure
    • if you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing
    • we may anonymise, aggregate and de-identify the data that we collect and use such anonymised, aggregated and de-identified data for our own internal business purposes, including sharing it with our current and prospective clients, business partners and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyse patterns among groups of people, and conducting research on demographics, interests and behaviour
    • to (a) comply with legal obligations; (b) respond to requests from competent authorities; (d) protect our operations; (e) protect our rights, safety or property, you or others; and (f) enforcing or defending legal rights, or preventing damage
    • We may use your personal data for other purposes which you have consented to at the time of providing your data.

    As used in this Privacy Policy, “legitimate interests” means the interests of Cultivate London in conducting and managing our organisation. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object at any time to processing of your personal data that is based on our legitimate interests, on grounds relating to your particular situation (for more information on your rights, please see “Your Data Protection Rights” section below).

    1. DISCLOSURE OF YOUR INFORMATION

    We share your personal data with third parties in the following situations:

    Disclosure for Law Enforcement
    Under certain circumstances, Cultivate London may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

    Legal Requirements
    Cultivate London Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:

    • To comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process
    • To enforce our Terms & Conditions or other applicable contract terms that you are subject to
    • To protect and defend the rights or property of Cultivate London Ltd
    • To prevent or investigate possible wrongdoing in connection with the Service
    • To protect the personal safety of users of the Service or the public
    • To protect against legal liability

    Service Providers
    Cultivate London, like many businesses, sometimes employs selected third party companies and individuals who act on our behalf to support our operations, such as (i) IT suppliers and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide services available on this Site, (ii) web analytics providers to monitor and analyze the use of our Service, (iii) providers of digital advertising services and (iv) providers of CRM, marketing and sales software solutions. Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide and are obligated not to disclose or use it for any other purpose.

    Google Analytics
    Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

    You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

    For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/

    1. PERSONAL DATA TRANSFERS

    Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

    If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.

    Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

    We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

    1. LINKS TO OTHER SITES

    Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

    We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

    1. SECURITY

    The security of your data is important to us, but remember that unfortunately no method of transmission or electronic storage of information over the internet or public communications networks can never be completely secure. We will take appropriate technical and organisational security measures to protect the personal data that you submit to us against unauthorised/unlawful access or loss, destruction or damage, although we cannot 100% guarantee the security of personal data that you provide to us online.

    1. PERSONAL DATA RETENTION

    We will keep your personal data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy, or for the duration required by any legal, regulatory, accounting or reporting requirements, whichever is the longer. When you consent to receive marketing communications, we will keep your data until you unsubscribe.

    We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

    Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.

    1. YOUR PERSONAL DATA PROTECTION RIGHTS

    Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to the GDPR, you have the following rights in relation to your personal data:

    • Right of access: If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details such as the purpose of the data processing. If you require additional copies, we may need to charge a reasonable fee.
    • Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
    • Right to erasure: You may ask us to delete or remove your personal data, such as where our legal basis for the processing is your consent and you withdraw consent. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data with so you can contact them directly. We may continue processing personal data where this is necessary for a legitimate interest in doing so, as described in this Privacy Policy.
    • Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the personal data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.
    • Right to data portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will provide you with your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
    • Right to object: You may ask us at any time to stop processing your personal data, and we will do so:
      o If we are relying on a legitimate interest to process your personal data — unless we demonstrate compelling legitimate grounds for the processing or
      o If we are processing your personal data for direct marketing.
    • Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
    • Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to the UK data protection authority (the Information Commissioner’s Office or ICO), or, as the case may be, any other competent data protection authority of an EU member state that is authorised to hear those concerns (you may find EU Data Protection Authorities’ contact information here.)

    If you wish to exercise any of these rights please contact us as described in the “Contact” section below. We may also need to ask you for further information to verify your identity before we can respond to any request.

    1. CHILDREN’S PRIVACY

    Our Service does not address anyone under the age of 13 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

    1. CHANGES TO OUR PRIVACY POLICY

    We may update our Privacy Policy from time to time. Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check back frequently to see any updates or modifications. If required by the applicable law, we will notify you of any material or substantive changes to this Privacy Policy.

    1. CONTACT

    Questions, comments or requests regarding this Privacy Policy should be addressed to data@cultivatelondon.org