Our Data Protection Policy describes the categories of personal data we process and for what purposes. We are committed to collecting and using such data fairly and in accordance with the requirements of the relevant domestic and European data protection laws and regulations, including GDPR.
This Data Protection Policy applies to personal data we process regardless of the media on which is stored or whether it relates to past or present employees, workers, customers, clients or supplier contracts, website users or any other data subject.
This Data Protection Policy sets out what we expect from you in order for the Company to comply with the applicable law. Your compliance with this policy is mandatory.
This Data Protection Policy does not override any applicable national data protection privacy laws and regulations in countries where The Past operates.
We take your privacy seriously and protecting the confidentiality and integrity of personal data is a critical responsibility. You can find out more here and in other related policies and notices about your privacy rights and how we gather, use and share your personal information – that includes the personal information we already hold about you now and the further personal information we might collect about you, either from you or from a third party. How we use your personal information will depend on the products and services we provide to you.
Our Data Protection Manager (DPM) is responsible for overseeing this policy. The DPM provides help and guidance to make sure we apply the best standards to protecting your personal information. If you have any questions or concerns about how we use your personal information our DPM can be reached by email at firstname.lastname@example.org or by post at Data Protection Manager, The Past Ltd, Office 120, 295 Chiswick High Road, London, W4 4HH.
This policy provides up to date information about how we use your personal information and will update any previous information we have given you about using your personal information (also referred to as personal data).
2. About us
We are what is known as the ‘data controller’ of personal information we gather and use. In some instances we are also the ‘data processor’ meaning that we process the personal information we collect and hold. When we say ‘we’ or ‘us’ in this policy, we mean The Past Ltd, Office 120, 295 Chiswick High Road, London, W4 4HH.
3. Your privacy rights
You have the right to object to how we use your personal information. If we have relied on consent to process your personal information you can withdraw that consent at any time (this is discussed further below). You also have the right to see what personal information we hold about you. In addition, you can ask us to correct inaccuracies, delete or restrict personal information or to ask for some of your personal information to be provided to someone else. You can make a complaint to us via the details on our website:
You can also make a complaint to the data protection supervisory authority, the Information Commissioner’s Office, at https://ico.org.uk. To make enquiries for further information about exercising any of your rights in this policy please contact our DPM by post at The Past, Office 120, 295 Chiswick High Road, London, W4 4HH.
4. What kinds of personal information we use
The categories of Personal Data about you that we may Process include:
- Personal details: information that you provide to us for the purpose of registering with us, including: given name(s); preferred name; country.
- Contact details: information that you provide to us for the purpose of subscribing to our services, including: postal address; email address; telephone number
- Device details: device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to our websites
- Usage details: information about your visits and use of the websites including geographical location, referral source, length of visit, page views and website navigation
- Transactional details: information relating to transactions carried out between you and us on or in relation to our websites, including information relating to any purchases you make of our goods or services. On our websites, when collecting your credit card information or bank details for online purchases, The Past enables the use of Secure Sockets Layer (SSL) technology and industry-standard secured-server transactions that encrypt your Personal Data. To verify that you have a secure server connection, look for the locked padlock symbol at the bottom of your browser window or the HTTPS-prefix in the URL.
5. How we gather your personal information
We may collect Personal Data from you, such as your name, address and contact details when you register with one of our websites or when you choose to use the various services we provide. We also collect other types of Personal Data that you provide to us voluntarily, when, for instance, you make a purchase, respond to surveys and questionnaires, sign up to a newsletter, or enter a competition. If you provide us feedback regarding our websites or services, we will collect your name and email address in order to send you a reply.
We also may obtain some personal information from monitoring or recording calls and if we use CCTV. We may record or monitor phone calls with you for regulatory purposes, for training and to ensure and improve quality of service delivery, to ensure safety of our staff and customers, and to resolve queries or issues. We may also use CCTV on our premises to ensure the safety and security of our staff and customers.
6. How we use your personal information
The purposes for which we may Process Personal Data, subject to applicable law, include:
- Our websites: operating and managing our websites; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our websites;
- Provision of services to you: providing our websites and other services to you (including suggesting content that may be of interest to you, based on your past activity); communicating with you in relation to those services; recommending content that may be of interest to you. Such services include sending you marketing messages if you have given us permission to do so, processing your answers to quizzes and other competitions, and sending electronic newsletters and promotional emails to you;
- Marketing communications: communicating with you via means (including via email, text message, social media, direct mail or in person) information in which you may be interested, subject to ensuring such communications are provided to you in compliance with applicable law;
- Disclosing Personal Data to our customers: in accordance with the provisions of this Policy and applicable law, we may disclose certain Personal Data to our customers. With your prior express consent, we may provide your Personal Data to our customers for the purposes of enabling them to contact you with information that may be of interest to you;
- Customer service messages: we also use your Personal Data for customer service messages, and to notify you about updates to our services and to respond to your requests;
- Anonymous Data: we may create Anonymous Data from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to perform statistical analysis of users’ aggregate behaviour so that we may enhance the content of our services and improve site navigation. The Past reserves the right to use and disclose Anonymous Data to third parties at its discretion, in aggregate form.
If you elect to receive communications from us we may periodically send you free newsletters and emails that directly promote the use of our sites or the purchase of our products or services and may contain advertisements for third parties
7. Our legal basis for using your personal information
In processing your Personal Data in connection with the purposes set out in this policy, we may rely on one or more of the following legal bases, depending on the circumstances:
- We have obtained your prior express consent to Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way);
- The Processing is necessary in connection with any contract that you may enter into with us;
- The processing is required by applicable law;
- The processing is necessary to protect the vital interests of any individual; or
- We have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interest, fundamental rights or freedoms.
8. Our legitimate interest and your right to object
- Legitimate Interest means the interests of our company in conducting and managing our business to enable us to give you the best service, content and offers.
- For example, we have an interest in making sure our content and offers are relevant to you, so we may process your information to send you newsletters, marketing offers and partner promotions that are tailored to your specialist interests.
- When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests in our specialist content and offers – 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 are otherwise required or permitted by law.
- Whenever we process data for these purposes we will ensure that we keep your Personal Data rights in high regard and take account of these rights. You have the right to object to this processing. If you wish to do so you may opt-out from receiving future communications from us by writing to us or emailing us using the contact details provided below. You may also personally manage your preferences or opt-out of all future communications by following the ‘Update your preferences’ link or ‘Unsubscribe’ link included in the footer of every email that we send. Please note if you do object or opt-out then this may affect our ability to carry out these tasks for your benefit.
9. Sharing your personal information with or getting your personal information from others
We may disclose your Personal Data to other entities within The Past group, for legitimate business purposes (including providing services to you and operating our websites), in accordance with applicable law;
- legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
- third party Processors and service providers in order to fulfil your request such as to charge your credit card (if authorised by you), fulfil your order, and deliver electronic newsletters and promotional emails. These third parties are required under contract not to use your Personal Data other than to promote the services requested by The Past and to guarantee to our satisfaction that they have sufficient processes in place to ensure the security of your data while it is in their care. You expressly consent to the sharing of your Personal Data with our contractors and third party service providers for the purpose of providing services to you;
- any relevant party, law enforcement, agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;
- named third party competition prize donors where explicit consent has been given for data to be shared with these partners;
- if you send a testimonial or comment to us, we may post it on our websites or use it in advertising materials. We will attribute your testimonials to you by posting your first and last initial or your first name and last initial next to your testimonial on our site or advertising materials, if provided.
If you provide The Past with your contact details and agree to receive promotional messages, we may allow our affiliates or third party businesses to promote goods or services that we believe may be of interest to our customers. These communications will only ever come from The Past, even when they refer to third party products or services. Many customers appreciate the offerings they receive from such third parties; however, we allow you to opt out at any time of having your Personal Data offered to affiliated or unaffiliated third parties for the purposes of sending you relevant information and promotions. For information about how you can opt out of receiving these promotional messages, see details below.
10. How long we keep your personal information for
How long we keep your personal information for depends on the products and services we deliver to you. We will never retain your personal information for any longer than is necessary for the purposes we need to use it for. We monitor how long we keep personal information for and aim to comply with the legal framework for document retention.
11. Keeping you up to date
We will communicate with you about products and services we are delivering using any contact details you have given us – for example by post, email, text message, social media, and notifications on our website.
Where you have given us consent to receive marketing, you can withdraw consent and update your marketing and contact preferences by calling us directly. For contact details, visit our website on www.the-past.com
12. Your online activities