INTRODUCTION
Welcome to TEN’s privacy policy.
TEN respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our platform and tell you about your privacy rights and how the law protects you.
PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how TEN collects and processes your personal data through your use of this platform, including any data you may provide through this platform when you become a member of TEN or sign up to our newsletter or white papers.
It is important that you read this privacy policy together with any other policy we may provide 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 policy supplements other notices and privacy policies and is not intended to override them.
CONTROLLER
Anatomy HCD Limited T/A TEN is the controller and responsible for your personal data (collectively referred to as “TEN”, “we”, “us” or “our” in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise Your Legal Rights , please contact the data privacy manager using the details set out below.
CONTACT DETAILS
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: Anatomy HCD Limited T/A TEN
Email address: privacy@weareten.co.uk
Postal address: c/o TEN, Studio 7, Platform 9, Floor 6, Tower Point, 44 North Road, Brighton BN1 1YR.
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.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. This version was created on 20th November 2018
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.
THIRD-PARTY LINKS
The platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our platform, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific feature of the platform. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
This platform is not intended for children and we do not knowingly collect data relating to children.
IF YOU FAIL TO PROVIDE PERSONAL DATA
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 services (for example, to provide you with access to the platform or other members or clients). 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.
We use different methods to collect data from and about you including through:
(i) analytics providers such as Google;
(ii) providers of technical, payment and delivery services such as Stripe Inc., Zoom inc, Slack inc.,Trint inc, Mailchimp inc. or Eventbrite; and
(iii) Companies House.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending 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.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To enroll you (and where applicable your team members) as a member | (a) Identity (b) Contact (c) Plan choice | Necessary for the performance of a contract with you |
| To process payment for your membership (and where applicable your team members) | (a) Identity (b) Contact (c) Financial | Necessary for the performance of a contract with you |
| To manage our relationship with you (for example to notify you about changes to our terms or privacy policy) - and where applicable your team members | (a) Identity (b) Contact (c) Marketing and Communications | Necessary for our legitimate interests (to keep our terms and policies up to date and to inform you of such changes) |
| To administer and protect our business and this platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | Necessary for our legitimate interests (for 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) |
| To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy to improve your experience of the platform) |
| To use data analytics to improve our platform, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our platform updated and relevant, to develop our business and to inform our marketing strategy to improve your experience of the platform) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing and Communications | Necessary for our legitimate interests (to develop our products/services and grow our business and offer you a better selection of goods or services) |
| To connect you to other members via the TEN platform and the TEN Slack channel | (a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Technical | Necessary for the performance of a contract with you |
| To invite you to face to face and virtual events | (a) Identity (b) Contact (c) Usage (d) Marketing and Communications (e) Technical | Necessary for the performance of a contract with you |
| To maintain and retain records in connection with legal claims and regulatory investigations; and for governance & compliance purposes. | (a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing and Communications | Necessary for the compliance of a legal obligation to which we are subject |
HOW THIRD PARTIES PROCESS YOUR PERSONAL DATA
In order to provide you with your membership, we may need to give your personal data to third parties who will process your data on our behalf, as set out in the table below.
For example, in order to process your payment we need to give your Financial Data to Stripe.
We require all third parties to respect the security of your personal data and to process it in accordance with the law. 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.
Certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
If you would like a full list of third parties who process your data please contact us thirdparties@weareten.co.uk
| Purpose/Activity | Type of data | Third Party data is given to | Lawful basis for processing |
|---|---|---|---|
| Fulfilling your application for membership (including processing payment) | (a) Contact Data (b) Financial Data | Stripe Inc. 185 Berry Street Suite 550 San Francisco, CA 94107 | Necessary for the performance of a contract |
| Fulfilling the management of your membership services (including all platform access) | (a) Identity Data (b) Contact Data (c) Financial Data (d) Technical Data (e) Usage Data (f) Marketing and Communications Data | OfficeRND Limited 4 Crown Place London EC2A 4BT | Necessary for the performance of a contract |
| Connecting you to other community members and clients | (a) Identity Data (b) Contact Data (c) Usage Data | Zoom Video Communications inc. 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113 | Legitimate interests |
| Connecting the TEN community to the global audience | (a) Contact Data (b) Technical Data (c) Usage Data (d) Marketing and Communications Data | Automattic Inc. (Wordpress) 60 29th Street #343 San Francisco, CA 94110 United States of America | Necessary for the performance of a contract |
| Connecting you to other community members, and sending you marketing communications | (a) Contact Data (b) Technical Data (c) Usage Data (d) Marketing and Communications Data | Eventbrite Inc. 155 5th Street, Floor 7 San Francisco, US | Legitimate interests |
| Connecting you to other community members, and sending you marketing communications | (a) Contact Data (b) Technical Data (c) Usage Data (d) Marketing and Communications Data | YouTube, LLC. 901 Cherry Ave. San Bruno, CA 94066. USA. | Legitimate interests |
| Connecting you to other community members for ongoing communications | (a) Identity Data (b) Contact Data (c) Technical Data (d) Usage Data | Slack Technologies Inc. 155 5th Street 6th Floor San Francisco, CA 94103 United States | Legitimate interests |
| Sending you marketing communications | (a) Contact Data | The Rocket Science Group LLC d/b/a MailChimp 675 Ponce de Leon Ave NE Suite 5000 Atlanta, GA 30308 USA | Legitimate interests |
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Marketing and Communications, Technical and Usage 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).
You will receive marketing communications from us if you have requested information from us or are a current member and you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING
We will get your express consent before we share your personal data with any third party for marketing purposes.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by logging into your platform account and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as part of our legitimate interests in keeping you informed and up to date (as set out above).
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this platform may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.
CHANGE OF PURPOSE
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 privacy@weareten.co.uk
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.
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 law.
We may disclose your personal data to 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 policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
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:
Please contact us privacy@weareten.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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.
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.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.
In some circumstances we will 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.
If you leave the platform we will no longer process information about you. When you leave we will remove your details from our platform in regard to membership.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
To request access to your personal data (commonly known as a “Subject Access Request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
To request confirmation as to whether or not your personal data is being processed.
To request the correction of your personal data that you consider to be inaccurate. This enables you to have any incomplete or inaccurate data we hold about you corrected. However, we may need to verify your identity and the accuracy of the new data you provide to us.
To request erasure of your personal data. This enables you to ask us to delete or remove personal data, including 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. These reasons will be notified to you at the time of your request.
To object to processing of your personal data. This enables you to object to the processing of your personal data if you feel it impacts on your fundamental rights and freedoms. In some cases, we may have compelling legitimate grounds to process your information which can override your right to object.
To request restriction of processing your personal data. This gives you the option to ask us to suspend the processing of your personal data e.g. if you want us to establish the data’s accuracy or you do not want us to erase it.
To request transfer of your personal data. If you request us to do so, we will provide to you, or a third party of your choice, your personal data in a commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use.
To withdraw consent to the processing of your data. If you request us to do so, we will no longer process your data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we will not be able to provide the services for you.
To not have a decision made about you based solely on automated processing.
If you wish to exercise any of the rights set out above, please contact us privacy@weareten.co.uk
NO FEE USUALLY REQUIRED
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 could refuse to comply with your request in these 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 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.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could 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.
LAWFUL BASIS
Legitimate Interest
means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract
means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation
means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.