Privacy Notice
Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
When we use personal data we are regulated by the Information Commissioner under the General Data Protection Regulation EU 2016/679 as it forms part of the laws of the United Kingdom by virtue of section 3 of the European Union (Withdrawal) Act 2018, including as further amended or modified by the laws of the United Kingdom or a part of the United Kingdom from time to time (UK GDPR) and the Data Protection Act 2018 (together, Data Protection Legislation). We are accountable as Controller of that personal data for the purposes of Data Protection legislation.
What this Privacy Notice applies to
This privacy notice relates to your use of our website and platform only.
Throughout our website and/or platform we may link to other websites owned and operated by certain trusted third parties. Those third party websites may also gather information about you in accordance with their own separate privacy notices. For privacy information relating to those third party websites, please consult their privacy notices as appropriate.
Key Terms
It would be helpful to start by explaining some key terms used in this notice:
We, us, our
means Socially United Limited, trading as Podium, a limited company incorporated in England and Wales under registered number 12207465 with registered office at Lynton House, 7-12 Tavistock Square, London, United Kingdom, WC1H 9BQ
Personal data
means any information relating to an identified or identifiable natural person.
Personal data we collect
In the course of your interaction with us and your use of our website and/or platform we will collect from you the following personal data:
- your name, address and contact information, including email address and telephone number when you sign up to our website and/or platform;
- information to check and verify your identity, e.g. date of birth;
- location data, if you choose to give this to us;
- details of any information, feedback or other matters you give to us by phone, email, post or via social media;
- your account details, such as username and login details;
- your activities on, and use of, our website;
- information about the services we provide to you;
- information about how you use our website and/or platform technology systems; and
- your responses to surveys, competitions and promotions.
This personal data is required to enable us to provide our services or to perform our contract with you. If we are not provided with the personal data we ask for, it may delay or prevent us from providing the services which you are requesting or performing our contractual obligations towards you.
How we collect your personal data
We collect your personal data:
- directly when you interact with us via our website and/or platform, such as when you sign up for a subscription with us, contact us (including via email), send us feedback, post material to the website and/or platform and complete customer surveys or participate in competitions via the website and/or platform; and
- indirectly, such as your browsing activity while on our website and/or platform; we will usually collect information indirectly using other technologies. Go to "Manage Cookies" at the bottom of this page.
How and why we use personal data
Under Data Protection legislation, we can only use personal data if we have a legal basis for doing so. These are mandated by the legislation and include:
- your consent;
- for the performance of our contract with you or to take steps before entering into a contract;
- to comply with our legal and regulatory obligations; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use personal data, so long as this is not overridden by the data subject’s own rights and freedoms.
The list below explains what we use (process) personal data for (our purpose) and our legal basis for doing so:
Managing your account
Our purpose
Create and manage your account with us and provide services to you, communication and marketing
Our legal basis
To perform our contract with you or to take steps at your request before entering into a contract, to comply with our legal and regulatory obligations or for our legitimate interests
Verifying your identity
Our purpose
Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us
Our legal basis
For our legitimate interests, i.e. to minimise fraud that could be damaging for you and/or us
Legal
Our purpose
To enforce legal rights or defend or undertake legal proceedings
Our legal basis
Depending on the circumstances:
- to comply with our legal and regulatory obligations
- in other cases, for our legitimate interests, i.e. to protect our business, interests and rights
Statistical analysis
Our purpose
Statistical analysis to help us understand our customer base and customise our website and/or platform and its content to your particular preferences based on a record of your selected preferences or on your use of them and retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended
Our legal basis
Depending on the circumstances:
- your consent
- where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
If you have provided such a consent you may withdraw it at any time (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn)
Operations
Our purpose
Operational reasons, such as maintaining the operational effectiveness of our website and/or platform
Our legal basis
For our legitimate interests or those of a third party, e.g. to identify and remedy problems with our website and/or platform usage
Confidentiality of personal data
Our purpose
Ensuring the confidentiality of personal data
Our legal basis
For our legitimate interests or those of a third party, e.g. to prevent data breaches and to comply with our legal and regulatory obligations
Sharing your personal data
Our purpose
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency
In such cases information will be anonymised where possible and only shared where necessary
Our legal basis
Depending on the circumstances:
- to comply with our legal and regulatory obligations
- in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets
Compliying with legal and regulatory obligations
Our purpose
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant
Our legal basis
To comply with our legal and regulatory obligations
The above table does not apply to special category personal data, which we do not anticipate that we will process. Should this situation change, we will update this Privacy Notice.
Promotional Communications
We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.
We may use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.
We have a legitimate interest in using your personal data for marketing purposes. This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
- contacting us at info@bepodium.com; or
- using the ‘unsubscribe’ link in emails
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who we share personal data with
We only allow our external third parties to handle personal data if we are satisfied they take all appropriate measures to protect all personal data and only on our written instructions.
We may very occasionally disclose and exchange information with regulatory bodies to comply with our legal and regulatory obligations.
Where personal data is held
Personal data is kept in securely in a password protected environment. Where we engage cloud-based service providers, it is on the basis of a written Data Processing Agreement.
Many of our suppliers store data on servers which may be located outside the United Kingdom. For more information, including on how we safeguard personal data if it is transferred outside the UK, see below: ‘Transferring personal data out of the UK’.
Keeping personal data secure
The privacy and the security of personal data is our utmost priority, and we recognise our obligation to keep it secure and private.
We have put in place industry-standard security practices to prevent personal data from being accidentally lost or used or accessed unlawfully including password protection, multi factor authentication of users and access restriction or control. We limit access to any personal data to our employees and contractors with a genuine business need to access it and subject them to strict obligations of confidence.
How long personal data will be kept
We will retain billing and subscription information of users for the duration of our contractual relationship with those users and then a period of 6 years.
We will retain other personal data of users for only so long as they use our services or until consent is withdrawn.
When it is no longer necessary to retain personal data, we will delete it.
Transferring personal data out of the UK
Some of our third party providers may store our data on servers which may be located outside the UK.
These transfers are subject to special rules and safeguards under European and UK data protection law with which we fully comply. For more information regarding these rules, please contact Daina Hussey at data@bepodium.com
Rights
All data subjects have the following rights, which can be exercised free of charge:
Access
The right to be provided with a copy of personal data held on a data subject
Rectification
The right to require us to correct any mistakes in a data subject’s personal data
To be forgotten
The right to require us to delete personal data in certain situations
Restriction of processing
The right to require us to restrict processing of certain personal data in certain circumstances, e.g. if the accuracy of the data is contested
Data portability
The right to receive the personal data provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object
The right to object:
- at any time to personal data being processed for direct marketing (including profiling);
- in certain other situations to our continued processing of personal data, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning a data subject
To withdraw consent
The right to withdraw consent as a legal basis for processing, at any time
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
To exercise any of those rights, please contact us —see below: ‘How to contact us’.
How to complain
We hope that we can resolve any query or concern raised about our use of personal information.
The General Data Protection Regulation also gives the right to lodge a complaint with a supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
Changes to this Privacy Policy
We may change this privacy policy from time to time, when we do we will inform data subjects via our website.
How to contact us
We can be contacted by email or telephone.
For all data subject rights, please contact Daina Hussey
Our contact details are shown below:
Email: data@bepodium.com