PRIVACY POLICY
Date last revised: October 2018

ALETHYA LIMITED (we/us/our) operates the website located at www.alethya.com (Alethya/Website). We are committed to respecting your privacy and protecting your personal data. We recognise that your personal data is your property and that you have loaned it to us for specific purposes. As such, you will be able to choose the information that is displayed in your profile and who can see it.
Unless otherwise required by law, the Information Commissioner’s Office (ICO) guidance or best practice, or in order to perform our contract with you, we will only process your personal data in the way we tell you or in the way you ask us to, and we will give it back to you at any time.

1. This policy

1.1 This is the privacy policy referred to in section 2.2.2 of our Terms of Use (available on our Website at www.alethya.com/terms-of-use). It sets out how we will process the personal data we take from you during your use of Alethya, and it is one of the documents that governs your use of our Website.
1.2 This policy therefore applies to our contract with you and you are advised to read it carefully. Terms used within it shall have the meaning(s) given in the Data Protection Act 2018 (Act) and/or the General Data Protection Regulation (Regulation), as applicable.
1.3 By visiting our Website, registering to use Alethya, or by otherwise providing your personal data to us, you understand, accept and consent to the practices described in this policy.
1.4 Any changes we make to this policy will be posted on this page. You are advised to check back frequently as, unless your consent is required, any changes will be binding on you when you continue to use the Website or work with us after the date of the relevant change.
1.5 For more information relating to your rights under this policy, please see section 9.
1.6 If you have any queries relating to this policy, please contact us at hello AT alethya.com in the first instance.

2. Who we are

2.1 For the purposes of the Act, the data controller is Alethya Limited. We are a UK registered, private limited company (number 10928115) and our registered office is at 124 Halford Road, London SW6 1JX.
2.2 We are registered with the ICO to process your personal data and our registration number is ZA461498.
2.3 Your personal data will be held and stored by us in our databases, on servers held by Google Cloud in a MySQL database, located in Ireland.
2.4 All data stored within our databases will be accessible by all of our staff, who are based in the UK. Staff access is granted by secure, unique login details only to those staff who receive appropriate training on the platforms we use to operate Alethya.

3. Your consent

3.1 We do not ordinarily rely on your consent to process your non-sensitive (or non-special category) personal data (as defined in the Regulation). This is because we process your personal data primarily to enable you to use Alethya and the Regulation permits us to process that data on this basis.
3.2 We do rely on your express consent to process the special category data (listed in section 4 and contained on our registration form). This consent is given by you on registration, and refreshed at regular intervals thereafter.
3.3 We consider the personal data we obtain from you on our registration form at the start of your use of Alethya is reasonable and necessary for these purposes. However, we review this intermittently and remove any inaccurate or obsolete data.
3.4 By using Alethya, we ask you to accept this privacy policy on registration. This is to be sure that you are aware of, and expressly consent to:
(a) how we process your personal data (including your sensitive or “special category” personal data);
(b) who we transfer your personal data to, and for what reasons; and
(c) how we keep your data secure.
3.5 You may exercise your rights under section 9 at any time. However, where you wish to object to how we process your personal data, this may prevent us from providing you with access to Alethya (in which case, we may need to disable or close your account).

4. What we collect

4.1 On registration, we will collect basic contact details from you in order to verify your identity. This includes your full name, date of birth, home and email addresses. All information we request is made clear to you in our registration form.
4.2 On registration, we additionally request from you special category personal data relating to your gender, your gender identity, gender and sexual preferences (orientation) and other information relating to your sexual and relationship history. We also ask you to upload a short summary explaining who you are and what you are looking to achieve from using Alethya.
4.3 Where you are a current, potential or former employee, worker or other member of our staff, we may collect additional categories of your personal data for the purposes of providing you with the necessary benefits under our contract with you. In those circumstances, a separate privacy notice applies and a copy is available on request.
4.4 Any bank or credit or debit card details that you provide to us in order to make payment for any events or merchandise through Alethya will be retained by our authorised payment processor and not by us (other than the expiry date and last 4 digits of the relevant card). This is in line with PCI DSS standards.

5. How we collect your data

The categories of personal data listed in section 4 are collected in the following ways:

5.1 When you provide it to us

• When you register to use Alethya, we will require your full name, date of birth, address and email contact details. This allows us to verify who you are and to correspond with you when using our Website.
• All other information relating to your gender, sexual orientation and preferences are obtained directly from you.
• Whenever you correspond with us, any personal data contained in that correspondence (including your IP address and location) will be retained by us.
• Where you buy and products, or register to attend any events, you will provide us with the personal data requested on checkout or confirmation.

5.2 When we collect it from you

• When you use our Website, we will automatically collect technical information about the device you use to visit, including your IP address, browser type/version and related settings.
• We also monitor your use of our Website. This includes the full URLs, your clickstreams through our Website, the pages you view and how you interact with them and how you leave the Website.
• During your use of Alethya, each user will generate metadata from tags, posts and comments on content. We will collect, aggregate and analyse this data (which has been manifestly made public by the user) for website monitoring purposes.

5.3 The following third parties provide your personal data to us, or we disclose it to them for the reasons listed:

• CloudSQL (by Google Cloud), is a storage solution hosted by Google LLC (Google) who are based in the United States of America (California). They host our email database from servers located in Ireland. More information about the security and privacy of your data held by Google is available at https://policies.google.com/privacy;
• Whenever we operate or advertise an event through Alethya that we think may be of interest to you (based on the information and preferences you provided to us on registration), we will disclose your name and contact details to the event organiser for the purposes of advertising the event (where you give us permission to do so). We only operate events with third parties with whom we work closely and can trust.

5.4 We will use Google Analytics, a web analytics service provided by Google, which uses “cookies” (alpha-numeric text files placed on your computer’s hard drive) to help analyse how you use the Website. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google on servers in the USA. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on your activity for us and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this your ability to use the Website may be restricted. By using the Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

6. Our use of cookies
6.1 The Website uses cookies to distinguish you from other users. This helps us provide you with a good experience whilst browsing, and allows us to improve it. By continuing to use our Website, you agree to our use of cookies.
6.2 We use the following cookies on Alethya:

• Targeting cookies – these cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make it, and the advertising displayed on it, more relevant to your interests.
• Functionality cookies – these are used to recognise you when you return to the Website. This enables us to personalise its content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Analytical/performance cookies – they allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works (for example, by ensuring that users are finding what they are looking for easily); and
• Strictly necessary cookies – these are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas, use a shopping cart or make use of e-billing services.

6.3 You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Website.

7. What we use your data for

7.1 Your personal data is primarily required to enable us to verify who you are for the purposes of using Alethya. It is also to provide support you have requested from us, and to contact you in relation to any enquiries or requests you raise with us.
7.2 Special category data is used to make Alethya more responsive, and appropriately filtered, to your interests and preferences. This is to allow you to connect with people who have similar interests to yourself.
7.3 Technical information we collect about your visit to Alethya is used to enable us to:
• personalise and improve its functionality and security (to keep it safe and secure);
• administer and monitor traffic and behaviours on our Website for analysis, testing, research, statistical and survey purposes; and
• ensure that we can offer you the most effective and efficient browsing experience, and make improvements where necessary.
7.4 Once collected, your personal data will be retained by us for as long as is necessary for you to use Alethya. After your account is closed or disabled, the data will be retained for up to 12 months, when it will be securely deleted and we will not contact you unless you ask us to.
7.5 To ensure the data we hold about you is accurate, we ask you to update your details and preferences at regular intervals. This is done when you login at specified intervals, with access to Alethya temporarily suspended until such time as your details have been updated.

8. How we keep your data safe

Our databases held with Google are ISO27001 accredited (the highest level of international accreditation available). All data held within that database is encrypted at rest.

9. How and why we disclose your data

9.1 The only third parties to whom we disclose personal data are those listed in section 5.4, for the purposes listed in that section.
9.2 Any websites which are linked from the Website are outside of our control and not covered by this policy. If you access those websites using the links provided, the website operators may collect information from you which will be used by them in accordance with their own privacy policies (if any). These policies may differ from ours, and we cannot accept any responsibility or liability in respect of these.

10. Your rights

10.1 In relation to all of your personal data, you have the following rights (in addition to any rights you may have under the Act or the Regulation) to ask us:
a) not to process your personal data for marketing purposes;
b) to clarify what data we hold about you, how it was obtained, to whom it has been disclosed and for how long it will be stored;
c) to amend any inaccurate data we hold about you;
d) to delete any of your data (where you no longer think we need to hold it, or you think we have obtained or processed it without your consent at any time); and
e) to only process your personal data in limited circumstances, for limited purposes.
10.2 We have the capacity to extract your personal data from our databases and provide it to you in a structured, commonly-used way (typically by .csv file).
10.3 If you wish to exercise any of your rights at any time, please contact us on the details contained at the beginning of this policy in the first instance. We will require you to verify your identity to us before we provide any personal data, and reserve the right to ask you to specify the types of personal data to which your request relates.
10.4 Where you wish to exercise any of your rights, they may be subject to payment of a nominal administration fee (to cover our costs incurred in processing your request) and any clarification we may reasonably require in relation to your request. Such fees may be charged where we consider (acting reasonably) that your request is excessive, unfounded or repetitive.