RED January : Privacy Policy

Privacy Policy

This Privacy Notice (“Privacy Notice”) applies to users of the RED January website at https://join.redjanuary.com (“Site”) and any of the services we offer, including from the Site (“Services”). We respect the privacy of our Site visitors, Facebook Group members and every person who uses our Services, and we are committed to ensuring a safe online experience for all.

Purpose of this privacy notice

This Privacy Notice 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 Notice also sets out your rights in respect of our processing of your personal information. For more information see below.

This Privacy Notice informs you of the nature of the personal information about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it.

This Privacy Notice 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. It should be read in conjunction with our Cookie Policy.

This Privacy Notice only applies to the use of your personal information obtained by us, whether from you directly or from a third party. It does not apply to personal information collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links to third party websites over which we have no control, or you purchase goods or services from those third parties).

About us

The Site and our Services are made available by RED January (“RED”, “we”, “us, “our”). RED is the data controller responsible for your personal information. For more information see below.

RED is registered as a fee payer with the UK Information Commissioner’s Office under registration number ZA462560. The register is publicly available here: https://ico.org.uk/ESDWebPages/Search

How to contact us

If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, please send us an email to hello@redtogether.co.uk.

Who we collect personal information about

We collect and process personal information from the following people:

Site visitors and users of our Services. For more information see below.

If you browse our Site, contact us with an enquiry through our Site or use any Services (available on our Site or otherwise), we will collect and process your personal information in connection with your interaction with us and our Site.

Members of our Facebook Group. For more information see below.

If you sign up to join our Facebook group at www.facebook.com/groups/runeverydayjanuary/(“Facebook Group”), we will collect and process your personal information in connection with your membership of the group and our interactions with you in relation to our Facebook Group.

Suppliers (including subcontractors). For more information see below.

If you supply products or services to us on your own behalf, we will collect and process your personal information in connection with our receipt of products and services from you and, where relevant, our provision of our Services to others.

Individuals who work for our partners and suppliers. For more information see below.

Corporate entities and other organisations are not data subjects, although any individuals who work for them are. If you work for or otherwise represent an organisation which is one of our partners or suppliers and you are engaging with us on behalf of that organisation, whether through our Site or otherwise, we will collect and process your personal information in connection with our receipt or provision of products and services and our wider relationship with your organisation.

Job applicants. For more information see below.

If you apply for a job with us, whether through the Site or otherwise, we will collect and process your personal information in connection with your application.

Personal information we collect and how we use it

Our primary reasons for collecting personal information from you is to: (i) provide our Services to you and others; (ii) verify your identity (where applicable); (iii) help us improve our Site and our Services and develop and market new products and services; (iv) carry out requests made on our Site; (v) investigate or settle enquiries or disputes; (vi) comply with applicable law, court order, other judicial process and the requirements of regulators; (vii) enforce our agreements with you; (viii) protect the rights, property and safety of us or third parties, including users of our Site and Services; (ix) provide support for the provision of our Services; (x) carry out recruitment activities; and (xi) use as otherwise required or permitted by law.

In particular, we use your personal information for the following purposes:

Fulfilment of our Services. For more information see below.

Use of our Site

We collect and maintain personal information that you voluntarily submit to us during your use of our Site and the Services we offer (on our Site or otherwise), whether for yourself or on behalf of any organisation you represent.

Use of our Facebook Group

Our Facebook Group (at www.facebook.com/groups/runeverydayjanuary/ is a closed group. If you apply to join our Facebook Group, we will process your personal information (including your name and social media handle and any other personal information you may volunteer) for the purpose of considering your application. If we accept your application, you will be added as a member of our Facebook Group and your membership and your Facebook account will be visible to other members. Your access to and interactions with our Facebook group are also subject to Facebook’s Terms and Conditions and Privacy Notice.

From time to time, we may ask your permission to re-use any photographs, quotes and testimonials you post to our Facebook Group. Where you give permission, we will publish such materials (together with your name), on our Site and in any print or digital newsletter or other publication we may publish from time to time.

Provision of our Services

We process your name and contact information (including email address and telephone number) and, where applicable, your payment information, so that we can fulfil the supply of Services you have requested from us, including through our Site. Certain Services are also subject to separate terms and conditions which will apply to your use of such Services.

Participating in our campaigns and events

If you sign up for any of our campaigns or events, we will process your name and contact information (including email address, postal address and telephone number) to communicate with you about the campaign or event, to record your participation in the campaign and/or your attendance at the event and for related record-keeping purposes. If relevant, we may collect and process any dietary requirements you may have.

You may also feature in photographs taken at our events and such photographs, together with your name and any quote or testimonial you may provide, may be published on our Site, our Facebook Group and in any print or digital newsletter or other publication we may publish from time to time for the purpose of post-event publicity.

Our legal basis for processing

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, or it is in our legitimate interest or a third party’s legitimate interest to use personal information in such a way to ensure that we provide the Services requested by you and others in an effective and efficient way.

If we ask your permission to use photographs, quotes and testimonials that you post to our Facebook Group, then our processing of such personal information will be based on consent.

General enquiries. For more information see below.

Our Site features a “Contact Us” page which invites you to submit enquiries about our Site, our organisation and our Services by email. We also accept enquiries by email, using the contact details available in the “How to Contact Us” section above. When you make an enquiry, we will collect and process your name, contact information (including email address and/or telephone number), the name of your organisation and any personal information you volunteer that is relevant to your enquiry. We use this information to manage and respond to your enquiries and requests.

Our legal basis for processing

It is in our legitimate interest to use your personal information in such a way to ensure that we are able to help you with your enquiry and provide a good standard of service to you.

Surveys and feedback. For more information see below.

From time to time, we will invite you to provide feedback about us or our Site or Services in the form of online surveys. We will collect and process your name and contact details (including email address, postal address and telephone number, as applicable) and any other personal information you choose to volunteer in your survey response or other feedback.

We use this information to help us improve the quality of service provided by our personnel. We also use your feedback to monitor and improve the quality of our Site and Services and to assist with the selection of future product and service lines.

Our legal basis for processing

It is in our legitimate interest to use the personal information provided by you in your feedback for the purposes described above.

Insight and analysis. For more information see below.

We analyse your contact details with other personal information that we observe about you from your interactions with our Site, our Facebook Page, our email communications and/or with our Services.

Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile device. This includes the following:

an IP address to monitor Site traffic and volume;
a session ID to track usage statistics on our Site; and
information regarding your personal or professional interests, demographics, experiences with our Services and contact preferences.

Our web pages and emails may contain cookies, web beacons and pixel tags (“Tags”). Tags allow us to 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.

Please see our Cookie Policy for further information.

This information is used to create insights about our visitors’ browsing habits on our Site. 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 Site and Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of features and functionalities our visitors like to see.

We also use this information to help us with the selection of future product and service lines and website design and to remember your preferences.

Our legal basis for processing

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. Please see our Cookie Policy for further details.

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 services to you and others.

We will only use your location data for insight and analysis purposes where we have your consent to do so.

Email marketing. For more information see below.

We carry out email marketing activities using your personal information. We use your name and email address to send you (or the organisation you represent) marketing communications by email, where you have consented to receive such marketing communications or where we have another lawful right to do so. Such communications will include information about our organisation, the Services we provide and the campaigns and events we offer from time to time.

Our legal basis for processing

We will only send you marketing communications by email where you have consented to receive such communications, or where we have another lawful right to do so.

Recruitment. For more information see below.

We use your personal information for recruitment purposes, in particular, to assess your suitability for any position for which you may apply for with us, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third party recruitment agency on your behalf. We also use your personal information to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.

We will process any personal information about you that you volunteer when you apply for a job with us. We may also process your personal information obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies, your referees and the Disclosure and Barring Service (if applicable).

The personal information we process may include your name and contact information (including your email address, postal address and telephone number), personal information concerning your education, qualifications and employment history and any other personal information which appears in your curriculum vitae and covering letter, which you volunteer in an application form or during an interview or which is contained in any reference we receive about you. Such information may also include special categories of personal information (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.

We also use your personal information for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.

Our legal basis for processing

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.

We will not process any special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

Receipt of services from suppliers. For more information see below.

If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal information in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Services to others.

The personal information we collect from you may include your name, job title, contact information (including email address, telephone number and postal address), bank account or other payment details and any other personal information you volunteer which is relevant to our relationship with you or the organisation you represent.

Our legal basis for processing

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 or the organisation you represent or it is in our legitimate interest to use personal information in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to provide our Services to you and others in an effective way.

Business administration and legal compliance. For more information see below.

We use your personal information for the following business administration and legal compliance purposes:

to comply with our legal obligations;
to enforce our legal rights;
to protect the rights of third parties; and
in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of all or a portion of our assets.

Our legal basis for processing

Where we use your personal information in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

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 the contact details we hold for you.

If you fail to provide your personal information

Where we are required by law to collect your personal information, or we need to collect your personal information under the terms of a contract we have with you, and you fail to provide that personal information when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal information we need in order to provide the Services you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the provision of the relevant Services to you, in which case we will notify you.

How we obtain your consent

Where our use of your personal information requires consent, you can provide such consent:

at the time we collect your personal information following the instructions provided; or
by informing us using the contact details set out in the “How to Contact Us” section above.

Our use of cookies and similar technologies

Our Site may use certain cookies, web beacons, pixel tags, log files and other technologies. Please see our Cookie Policy to find out more about the cookies and other technologies we use, the purposes for which we use them and how to manage, block or delete them.

Third party links and services

Our Site contains links to third party websites and services. When you use a link to go from our Site to another website or you request a service from a third party, this Privacy Notice no longer applies. For more information see below.

Your browsing and interactions 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. For example, our website invites you to connect with us on social media platforms such as Facebook, Twitter and LinkedIn. When you click on the links we provide to such platforms, you will be transferred from our Site to the relevant platform and the privacy notice (and other terms and conditions) of that platform will apply to you.

We do not monitor, control or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy notices and practices.

This Privacy Notice applies solely to personal information collected by us through our Site, the supply of our Services and/or in connection with our business operations and does not apply to these third party websites and third party service providers.

Sharing data

We will only share personal information with others when we are legally permitted to do so. When we share personal information with others, we put contractual arrangements and security mechanisms in place to protect the personal information shared and to comply with our data protection, confidentiality and security standards and obligations. For more information see below.

When processing your personal information we may need to share it with third parties as follows:

Third-party organisations that provide applications/functionality, data processing or IT services: We share personal information with third parties who support us in providing our Services and help provide, run and manage our internal IT systems. Such third parties may include, for example, providers of information technology, cloud-based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal information may be stored in any one of them. We also share your personal information with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Policy.

Payment providers and banks: We share personal information with third parties who assist us with the processing of payments and refunds.

Campaign and event partners: Where we run campaigns or events in partnership with other organisations, we will share your personal information with such organisations for use in relation to the operation and administration of that event or campaign.

Third-party email marketing and CRM specialists: We share personal information with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communciations.

Event management and ticketing services: We share personal information third-party suppliers who help manage any events that we host, including to send out invites to those events and to provide online ticket booking services.

Recruitment agencies and related organisations: We share personal information with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies.

Auditors, lawyers, accountants and other professional advisers: We share personal information with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.

Law enforcement or other government and regulatory agencies and bodies: We share personal information with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.

Other third parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal information, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal information where we are permitted to do so in accordance with applicable law or regulation.

This list is non-exhaustive and there may be circumstances where we need to share personal information with other third parties in order to operate our Site and provide our Services.

Transfers outside the European Economic Area (“EEA”)

Where necessary in order to deliver our Services, we will transfer personal information to countries outside the EEA.

Non-EEA countries do not have the same data protection laws as the United Kingdom and the EEA. However, when transferring your personal information outside the EEA, we will comply with our legal and regulatory obligations in relation to your 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.

We will take reasonable steps to ensure the security of your personal information in accordance with applicable data protection laws. For more information see below.

When transferring your personal information outside the EEA, we will ensure that at least one of the following safeguards is implemented:

Adequacy decisions: 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. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

Model clauses: 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 https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

EU-U.S. Privacy Shield: 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 Europe and the US. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en.

Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data out of the EEA.

How long we keep your personal information

Regarding personal information we have processed in connection with the supply of our Services to, we will retain personal information relevant to that supply of Services for six years from the date of supply and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.

Regarding any other personal information we have processed, we will retain relevant personal information for three years from the date of our last interaction with the relevant individual and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability.

If any personal information is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we may delete it at the end of that period.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal information indefinitely so we know not to send you further marketing communications in the future.

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. For more information see below.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

unauthorised access;
improper use or disclosure;
unauthorised modification; and
unlawful destruction or accidental loss.

All 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 Site and our Services.

Personal information of children

This Site is not intended for children and we do not knowingly collect personal information relating to individuals under the age of 18. Please do not submit personal information to us if you are under the age of 18.

How to access your information and your other rights

You have the following rights in relation to the personal information we hold about you:

Your right of access. For more information see below.

If you ask us, we will confirm whether we are 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 charge a reasonable fee for producing those additional copies.

Your right to rectification. For more information see below.

If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have 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 will also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to erasure. For more information see below.

You can ask us to delete or remove your personal information in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

Your right to restrict processing. For more information see below.

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 will tell you before we lift any restriction. If we have shared your personal information with others, we will 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 will also tell you who we have shared your personal information with so that you can contact them directly.

Your right to data portability. For more information see below.

You have the right, in certain circumstances, to obtain personal information you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.

Your right to object. For more information see below.

You can ask us to stop processing your personal information, and we will do so, if we are:

relying on our own or someone else’s legitimate interest to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
processing your personal information for the purposes direct marketing.

Your rights in relation to automated decision-making and profiling. For more information see below.

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

Your right to withdraw consent. For more information see below.

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. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.

Your right to lodge a complaint with the supervisory authority. For more information see below.

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal information, please contact us using the contact details provided in the “How to Contact Us” section above. You can also report any issues or concerns to the Information Commissioner’s Office (ICO). You can find details about how to report a concern on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113. You can find a list of contact details for all EU supervisory authorities at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Changes to this Privacy Notice

We may make changes to this Privacy Notice from time to time. For more information see below.

To ensure that you are always aware of how we use your personal information we will update this Privacy Notice 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 Notice periodically to be informed of how we use your personal information.