Virtual Auxilium Privacy Notice
Conquering Steps Ltd recognises that privacy is an important concept in internet usage and is therefore committed to ensuring that the privacy of our users and members is protected
This privacy notice provides you with details of how we collect and process your personal data through your use of our site at conqueringsteps.com including any information you may provide through our sites or direct contact when you complete a contact form or contact us relating to our services.
By providing us with your data, you warrant to us that you are over 13 years of age.
Conquering Steps Ltd (herein referred to as Conquering Steps or the company) is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our full details are:
Full name of legal entity: Conquering Steps Ltd
Email address: firstname.lastname@example.org
Postal address: 1 Firgrove Walk, Cheltenham, Gloucestershire, GL51 6PJ
Websites to which this policy applies: conqueringsteps.com
We are registered under the Data Protection Act with the ICO.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
2. WHAT DATA DO WE COLLECT ABOUT YOU
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of personal data about you as follows:
- Identity Data may include your first name, last name, username, marital status, title, date of birth and gender.
- Contact Data may include your billing address, delivery address, email address and telephone numbers.
- Financial Data may include your bank account and payment card details.
- Transaction Data may include details about payments between us and other details of purchases made by you.
- Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
- We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
We may collect sensitive data about you when working on a 1:1 or group basis which may refer to your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. We do not collect any information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or provide membership services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time
3. HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
- Complete a contact form via the website
- order our products or services
- subscribe to our service or publications;
- request resources or marketing be sent to you;
- enter a competition, prize draw, promotion, or survey; or
- give us feedback.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below
Technical Data from the following parties: MailChimp for Newsletters – Complies with the EU-US and Swiss Privacy Shield Frameworks, Google Analytics to review website traffic – Complies with the EU-US and Swiss Privacy Shield Frameworks.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between us.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at email@example.com
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
To process and deliver your order including managing payments, fees and charges or to collect and recover monies owed to us.
Type of data collected (a) identity, (b) contact (c) financial (d) transaction (e) marketing and communications.
Lawful basis for processing (a) Performance of a contract with you (b) Necessary for our legitimate interests to recover debts owed to us
Type of data collected (a) identity, (b) contact (c) profile (d) marketing and communications.
Lawful basis for processing (a) Performance of a contract with you (b) Necessary for our legitimate interests to keep records updated and to study how customers use our products and services and (c) necessary to comply with a legal obligation
To enable you to partake in a prize draw, competition or complete a survey
Type of data collected (a) identity, (b) contact (c) profile (d) marketing and communications (e) usage
Lawful basis for processing (a) Performance of a contract with you (b) Necessary for our legitimate interests to keep records updated and to study how customers use our products and services
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data
Type of data collected (a) identity, (b) Contact (c) technical
Lawful basis for processing (a) necessary for our legitimate interests for running our business, provision of administration and IT services, network security, or to prevent fraud in the context of business, reorganisation or group restructuring exercise
To deliver relevant content and advertisments to you and measure and understand the effectiveness of our advertising
Type of data collected (a) identity, (b) contact (c) profile (d) usage (e) marketing and communications (f) technical
Lawful basis for processing (a) necessary for our legitimate interests to study how customers use our products or services, to develop them, to grow our business and to inform/create our marketing strategy
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data collected (a) technical (b) usage
Lawful basis for processing (a) necessary for our legitimate interests to define types of
customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data collected (a) identity, (b) contact (c) technical (d) usage (e) profile
Lawful basis for processing (a) necessary for our legitimate interests to develop our products/services and grow our business
You will receive marketing communications from us if you have:
- requested information from us or purchased goods or services from us; or
- if you provided us with your details when you entered a competition or registered for a promotion or free resources; and
in each case, you have not opted out of receiving that marketing.
We do not share personal data with any third party for marketing purposes, if this however should there be a circumstance where this is required, we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or OR by emailing us at support@virtualauxilium at any time
Where you opt-out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at support@virtualauxilium
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Siteground for website hosting. Namecheap for email hosting. Google Drive and Dropbox to store website backups, MailChimp for Newsletters. WordPress for Website design and set up. Stripe for online credit card payments and Xero for tax and invoicing.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Some of our third party service providers are based based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
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; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at support@virtualauxilium if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
- You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at email@example.com
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated
10. THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements, cookie policies or data retention. When you leave our website, we encourage you to read the privacy notice of every website you visit
What’s a cookie?
- A “cookie” is a piece of information that is stored on your computer’s hard drive and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
- Cookies are used by nearly all websites and do not harm your system.
If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. You can block cookies at any time 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 site.
Cookies are either:
Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or
Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. We use persistent cookies for Google Analytics.
Cookies can also be categorised as follows:
Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
Performance cookies: These cookies enable us to monitor and improve the performance of our website. For example, they allow us to count visits, identify traffic sources and see which parts of the site are most popular.
Functionality cookies: These cookies allow our website to remember choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
Your consent applies to the following domains: theasap.org.uk, hub.theasap.org.uk, asapwards.org.uk, asapconvention.org.uk, jobs.theasa.org.uk
In addition, we reserve the right to modify the information held on this web site without notice, and whilst we are willing to amend details on request by the original supplier of such details we provide no guarantees of how long it may take to effect such changes.
13. Our liability
The providers or our agents cannot accept responsibility for any loss, injury or damage sustained as a result of using any of the services provided on this web site, or by referrals to any other individual /organisation that appear on this website, whether financial, material, physical or mental.
The material displayed on our site is provided without any guarantees, conditions or warranties as to its accuracy. To the extent permitted by law, we, and third parties connected to us hereby expressly exclude:
- All conditions, warranties, and other terms which might otherwise be implied by statute, common law or the law of equity.
- Any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our site or in connection with the use, inability to use, or results of the use of our site, any websites linked to it and any materials posted on it, including, without limitation any liability for:
- loss of income or revenue;
- loss of business;
- loss of profits or contracts;
- loss of anticipated savings;
- loss of data;
- loss of goodwill;
- wasted management or office time; and
for any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above.
This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law.
14. Viruses, hacking and other offences
You must not misuse our site by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to our site, the server on which our site is stored or any server, computer or database connected to our site. You must not attack our site via a denial-of-service attack or a distributed denial-of service attack.
By breaching this provision, you would commit a criminal offence under the Computer Misuse Act 1990. We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use our site will cease immediately.
We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect your computer equipment, computer programs, data or other proprietary material due to your use of our site or to your downloading of any material posted on it, or on any website linked to it.
15. Jurisdiction and applicable law
The English courts will have non-exclusive jurisdiction over any claim arising from, or related to, a visit to our site.
All steps have been taken to ensure that the information published on this site is as accurate as possible. The providers or our agents cannot accept responsibility for any errors, omissions or inaccuracies or for any consequence arising as a result, to either those that choose to advertise here or those that use any of the services provided on this site or via ASAP membership.
Unless clearly stated, any opinions, recommendations, information or advice that appear on this site are not necessarily those of the providers of this site, and caution should be exercised before acting upon any opinions, recommendations, information or advice.
This site also contains links to other web sites which are completely independent of this web site and we make no representation or warranty as to the accuracy, completeness or authenticity of any opinions, recommendations, information or advice contained in any such linked web site. Furthermore, we do not endorse the opinions of third parties expressed on any web sites linked to.
Links to another web site, or introductions by way of the provision of an address or other contact details shall not be construed as an endorsement by us of that web site, individual or organization, or of the products or services described therein unless expressly stated on this site.
Wholesale reproduction of this site or any information contained within it is expressly forbidden. A limited amount of false information may deliberately appear on this site, to enable the providers to identify and protect by taking appropriate legal action, their intellectual property and any copyrights and trademarks that may exist.
The content of this privacy notice and all aspects of the copy on this website is copyrighted to Conquering Steps Ltd and should not be copied, duplicated, or used.