Privacy Notice

Who we are

This privacy notice is provided by Valley Leisure Limited which trades as I Can Connect. It explains what personal information we collect about you, how and why we collect, store, use and share your personal information, your rights in relation to your personal information and how to contact us or make a complaint. By 'personal information' we mean information which relates to you as an individual and tells us something about you.

Data protection basics

This privacy notice applies to our processing in the UK of personal information relating to individuals located in the UK and elsewhere.

When we process the personal information of these individuals, we are regulated under UK (and sometimes EU) data protection laws and we are responsible as 'controller' of that personal information for any processing undertaken by us or our staff for the purposes of those laws.

The personal information we collect, and the use we make of it, varies depending on our relationship with you. For that reason, this privacy notice distinguishes between users of our platform, individuals using the platform on someone else's behalf, website users, job applicants and emergency contacts of our users. Please be sure to read the sections of the privacy notice which relate to you.

Under data protection law, we can only use your personal information if we have a permitted legal basis for doing so, for example:

• Where you have given consent
• For the performance of our contract with you or to take steps at your request before entering into a contract
• To comply with our legal and regulatory obligations
• To protect your vital interests or those of another individual
• For our legitimate interests or those of a third party. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights.

Where we use "special category"; or personal information (such as information about your racial or ethnic origin, religious or philosophical beliefs, health or sexual orientation) we must also have a condition for doing so, for example:

• Where you have given consent
• For reasons of substantial public interest (for example, monitoring and promoting equality of opportunity or treatment)
• To exercise or defend legal claims

We explain in the section titled 'how and why we use your personal information' and 'how and why we use your sensitive personal information' our legal bases and condition for using your personal information.

Personal information we collect about you

The information we collect about you depends on who you are and will generally be provided by you, or someone (for example, a family member or friend) on your behalf. We will collect this information when you contact us through the website, by telephone, post, email or through any other means or when you use our services.

We will also collect some information automatically through the use of cookies. For further information, please see our cookies policy.

The information we collect may include:

For website users:

• IP address (automatically collected)
• Web browser type and version (automatically collected)
• Operating system (automatically collected)
• A list of URLs starting with a referring site, your activity on this website, and the site you exit to (automatically collected)
• Information contained in enquiries submitted to us via our website

For users of the I Can Connect platform

• Your name and contact details (address, email address and telephone number)
• Information about your use of the platform (classes and 1-1 sessions you have booked, attended and cancelled)
• Your billing and transaction information
• Information about your goals and the benefits of the platform that you provide to us
• Your image in video form (including audio)
• Your sex, date of birth and employment status, where you choose to provide these
• Your racial or ethnic origin, information about your physical and mental health, religious or philosophical beliefs and sexual orientation, where you choose to provide these

For individuals using the I Can Connect platform on behalf of someone else (for example, a family member or friend)

• Your name and contact details

For job applicants

• Your qualifications, employment history and other information contained in your curriculum vitae
• References
• Other personal information provided by you

For 'In Case of Emergency' contacts of users of the I Can Connect Platform

• your name and telephone number
• your relationship to the user of the platform

How and why we use your personal information

The table below explains what we use your personal information for and our legal basis for doing so:

How and why we use your sensitive personal information

What we use your personal information for	Our legal basis
Website users: To contact you regarding our services For technical and operational reasons such as allowing access to the secure area of our website or making use of e-billing services, to monitor the performance of our website and improve functionality (for example, recognising you when you return to our website)	For our legitimate interests or those of a third party For the performance of our contract with you or to take steps at your request before entering into a contract
Users of the I Can Connect platform: To contact and communicate with you To provide you and others with our services To administer your account and ensure payments have been made For operational reasons such as maintaining information security and maintenance of internal records To identify and review the existence or absence of equality of opportunity or treatment between groups using the platform	For the performance of our contract with you or to take steps at your request before entering into a contract For our legitimate interests or those of a third party With your consent To protect your or another person's vital interests
For individuals using the I Can Connect platform on behalf of someone else: To contact and communicate with you To provide others with our services	For the performance of our contract with you or to take steps at your request before entering into a contract For our legitimate interests or those of a third party
For job applicants: To assess your suitability for a job and to contact you in relation to that job	For the performance of our contract with you or to take steps at your request before entering into a contract For our legitimate interests or those of a third party
For "In Case of Emergency" contacts of users of the I Can Connect platform: To contact you	To protect the vital interests of an individual

What we use your personal information for	Our legal basis
Users of the I Can Connect platform: To provide you and others with our services To identify and review the existence or absence of equality of opportunity or treatment between groups using the platform	With your consent For reasons of substantial public interest To establish, exercise and defend our legal rights To protect the vital interests of an individual

Who we share your personal information with

We routinely share your personal information with the following for the following reasons:

• Our service providers including Cloud-based storage providers, IT support providers, marketing agencies and website hosts so that we can respond to enquiries appropriately;
• Our payment service provider, Go Cardless, for the purpose of administering payments. Their privacy policy can be viewed at https://gocardless.com/privacy/
• Our professional advisers including accountants and lawyers to ensure that we are complying with our legal and regulatory obligations
• Where appropriate, with employment agencies, previous employer, educational establishments and referees
• Law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations
• Potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible, however the recipient of the information will always be bound by confidentiality obligations
• Any third party to whom we assign or transfer our business.

Whether information must be provided by you and, if so, why

If you are a user of the I Can Connect platform, the provision of some personal information (including your contact details, details of your usage of the platform and payment information) is necessary primarily to enable us to provide you with our services. We do not require you to provide us with this information but if you choose not to, it may have an impact on our ability to provide you with our services in part or at all. In the case of information about your goals or equality information or your video/audio, we do not require you to provide this information and it will not impact on our ability to provide you with our services.

If you are a website user or an individual using the platform on behalf of someone else, we do not require you to provide us with information but if you choose not to, we may not be able to respond to with information about our services or provide services to a user of the platform.

If you are a job applicant, we need your personal information to consider your job application. Without it we cannot consider hiring you.

Keeping your personal information secure

We have robust security measures in place across our systems to protect your personal information from being accidentally lost, used or accessed unlawfully, for example:

• access to your account is controlled by a password and a username that is unique to you
• we store your personal information on secure servers
• our staff are subject to a duty of confidentiality

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How long we keep your personal information for

We keep your personal information for no longer than necessary for the purposes for which it was collected.

Generally this will be for seven years after the end of our relationship with you unless we are required by law to adopt a longer retention period, or we need the information for longer to respond to any questions, complaints or claims made by you or on your behalf.

If you are a job applicant, we will keep your personal information for a maximum of 1 year from the date when you first contact us in relation to a job. If you are accepted for a job, your personal information will be kept in accordance with our privacy notice for staff.

If you are an 'in case of emergency' contact, we will keep your personal information for as long as the user is subscribed to the platform.

If we process your personal information to send you marketing communications, we will keep it for as long as you are happy to hear from us. If you object to receiving marketing communications from us, we will stop contacting you.

When it is no longer necessary to retain your personal information, we will anonymise or securely delete it.

Transferring your personal information outside the UK

We will not usually transfer your personal information outside of the UK unless you request that we provide services to you whilst you are abroad.

Your Rights

You have the following rights in relation to your personal information, which you can exercise free of charge:

• Right to access - the right to be provided with a copy of your personal information.
• Right to rectification- the right to require us to correct any mistakes in your personal information.
• Right to be forgotten - the right to require us to delete your personal information in certain situations.
• Right to restrict our use of your personal information - the right require us to restrict processing of your personal information in certain circumstances, for example if you contest the accuracy of the information.
• Right to data portability - the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that information to a third party in certain situations.
• Right to object - the right to object at any time to your personal information being used for direct marketing purposes or, in certain other situations, to our continued processing of your personal information, for example processing carried out for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your personal information (where consent is our legal basis for processing), please:

• Email us – for our contact information, see How to contact us below
• Let us have enough information to identify you
• Tell us know what right you want to exercise and the information to which your request relates

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold it.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

The UK GDPR gives you a right to lodge a complaint complaint with the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/. If you live or work in the EU or EEA, you can also complain to your local supervisory authority.

Changes of business ownership and control

Valley Leisure Limited may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Valley Leisure Limited. Personal information provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the information for the purposes for which it was originally supplied to us.

Changes to this privacy notice

Valley Leisure Limited may change this privacy policy from time to time so please check it periodically.

How to contact us

Please contact us by email if you have any questions about this privacy notice or the information we hold about you, to exercise a right under data protection law or make a complaint. Our email address is info@icanconnect.co.uk