Image Library Privacy Notice
1. Introduction
• This privacy notice gives you information about how Rad Chat Limited has collected and will use the following categories of personal data about you:
• the Photograph(s) (as defined in the letter agreement between you and us to which this privacy notice is attached as Schedule 1); your Health Data; and your contact details and related personal data (the Related Personal Data).
• This privacy notice only relates to how we will process the Photograph(s), your Health Data and the Related Personal Data.
• It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, for example, if you are using our website so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
2. Important information and who we are
• Rad Chat Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice).
• If you have any questions about this privacy notice, including any requests to exercise your legal rights (paragraph 10), please contact us using the information set out in the contact details section (paragraph 11).
• You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), with respect to data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
• It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new email address.
3. The data we have collected and how it was obtained:
We have collected the Photograph(s), the Health Data and Related Personal Data which were provided to us by you.
4. How we will use your personal data:
We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:
• On the basis of your consent.
• 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. (For more information on the meaning of legitimate interests, see paragraph 10.)
• Where we need to comply with a legal or regulatory obligation.
We may process special categories of personal data (including your Health Data) where:
• we have your explicit consent;
• the processing is necessary for reasons of substantial public interest with a legal basis; and/or
• the processing is necessary for health or social care purposes with a legal basis; and/or
• the processing is necessary for the establishment, exercise, or defence of legal claims.
5. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. References to Permitted Activities and Permitted Purpose, Photograph(s) and Related Data are as defined in the letter agreement to which this privacy notice is attached as Schedule 1.
• This privacy notice gives you information about how Rad Chat Limited has collected and will use the following categories of personal data about you:
• the Photograph(s) (as defined in the letter agreement between you and us to which this privacy notice is attached as Schedule 1); your Health Data; and your contact details and related personal data (the Related Personal Data).
• This privacy notice only relates to how we will process the Photograph(s), your Health Data and the Related Personal Data.
• It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, for example, if you are using our website so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
2. Important information and who we are
• Rad Chat Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice).
• If you have any questions about this privacy notice, including any requests to exercise your legal rights (paragraph 10), please contact us using the information set out in the contact details section (paragraph 11).
• You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), with respect to data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
• It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new email address.
3. The data we have collected and how it was obtained:
We have collected the Photograph(s), the Health Data and Related Personal Data which were provided to us by you.
4. How we will use your personal data:
We will only use your personal data when the law allows us to. We will use your personal data in the following circumstances:
• On the basis of your consent.
• 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. (For more information on the meaning of legitimate interests, see paragraph 10.)
• Where we need to comply with a legal or regulatory obligation.
We may process special categories of personal data (including your Health Data) where:
• we have your explicit consent;
• the processing is necessary for reasons of substantial public interest with a legal basis; and/or
• the processing is necessary for health or social care purposes with a legal basis; and/or
• the processing is necessary for the establishment, exercise, or defence of legal claims.
5. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. References to Permitted Activities and Permitted Purpose, Photograph(s) and Related Data are as defined in the letter agreement to which this privacy notice is attached as Schedule 1.
6. Disclosures of your personal data
• We may have to share your personal data where necessary with the parties set out below for the purposes set out in the table in paragraph 5 above.
• External Third Parties as set out in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
• We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for the Permitted Purposes and in accordance with our instructions.
7. International transfers
We do not transfer your personal data outside the UK.
8. 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. 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.
9. Data retention
• We will retain the Photograph(s) and Related Data for as long as necessary to fulfil 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.
• In some circumstances you can ask us to delete your data: see your legal rights: see [paragraph 10] for further information.
• In some circumstances we will 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.
10. Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in paragraph 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
- If you want us to establish the data's accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us on rad_chat@outlook.com in writing. If we receive notification that you have withdrawn your consent to the use of the Photograph(s) for the Permitted Purpose, we will no longer process the Photograph(s) for the Permitted Purpose and, subject to our retention policy, we will dispose of the Photograph(s) securely. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
11. No fee usually required
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.
12. What we may need from you
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.
13. Time limit to respond
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.
14. Contact details
If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways: Email address: rad_chat@outlook.com Postal address: Rad Chat Limited, Unit 4 Broadfield Court, Sheffield S8 0XF
Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do 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 to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us using the information set out in the contact details section (paragraph 14).
Comply with a legal obligation or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Your consent
THIRD PARTIES
External Third Parties Service providers acting as processors based in the UK who provide IT and system administration services.
Regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.