Effective: 31st May 2020
This Policy has been written in accordance of the 1998 Data Protection act and updated in accordance with the requirements of EU General Data Protection Regulation (GDPR) effective from 31st May 2020.
What is Grow Together?
Grow Together is a small business that offers Baby Massage courses, Baby and Toddler Yoga classes and Tummy Time workshops. Our goal is to provide friendly and welcoming sessions to support all new and established parents.
Who provides the Services and controls my information?
Grow Together is operated and provided to you by Siobhan Buchanan. For the purposes of EU data protection law, Siobhan Buchanan is your data controller and data processor.
Grow Together may collect and use the following kinds of personal information from you and with your permission:
Information that a Parent/Legal Guardian providers for the purpose of registering with Grow Together for booking classes (name, email, address, phone)
Parents/Legal Guardians login details (username and password)
Information that Parents/Legal Guardians provide when booking a class through Grow Together (name, email, phone, child's name, child's age, child's gender, any other useful information (eg allergies)
Stripe account reference number of Parents/Legal Guardians if paying for classes through Happity booking system
Contact details of Parents/Legal Guardian if paying for classes through Paypal.
How we use your information
Grow Together may use the information it collects to:
Provide Instructors with the information from Parents/Legal Guardians about who has booked their classes for the purpose of class registers, payment tracking and class administration;
Provide a secure web account to Parents/Legal Guardians where they can book classes
Personalise the website for Parents/Legal Guardians who are connecting to the login area;
Send Parents/Legal Guardians a newsletter or email if they have consented to receiving contact through emails
Data about minors (under-16's)
When a Parent/Legal Guardian books a class, we ask you to provide some details about the child. This information is shared with the Instructor of the class you are booking for the purpose of ensuring that the class is within the specified age range for the class, for tracking payment and to create a class register. We or they do not communicate directly with the minor through the website. The information is provided with the consent of the Parent/Legal Guardian.
Our legal bases for collecting, using, sharing and otherwise processing your information
Grow Together will only collect, use, share, and otherwise process the information we have about you for the purposes described in this policy where legally permitted. These legal bases include:
For Grow Together to comply with a legal obligation, a court order, or to exercise and defend legal claims;
For Grow Together to comply with a contractual obligation with you
Where you have made the information manifestly public;
Where you have given consent; and
Where necessary for the purposes of Grow Together’s or a third party's legitimate interests.
Legitimate Interests include:
Grow Together’s legitimate interest in processing your data are:
To keep Instructor data up to date for the benefit of Parents/Legal Guardians;
To provide a seamless experience when you join Grow Together as a Parents/Legal Guardians
You benefit from a number of rights in relation to your information that we process. While some of these rights apply generally, certain rights apply only in certain limited cases. We describe these rights below.
If we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your data for direct marketing, you can always object by emailing us at email@example.com
Where you have previously provided your consent, you have the right to withdraw your consent to the processing of your information at any time. For example, you can withdraw your consent to email marketing by using the unsubscribe link in such communications. If you withdraw your consent to the use of your information for purposes set out in this Policy, you may not have access to all (or any) of our Services and we might not be able to provide you all (or any) of our Services. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.
If you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so by contacting the Information Commissioner's Office (or ICO) at www.ico.org.uk, but we would be grateful if you would contact us first so we can try to resolve it by emailing Grow Together on firstname.lastname@example.org
Marketing and spam.
We know that you do not want spam or marketing calls from third parties, so we will never sell or rent your contact information to third parties, and we won't share it with a third party unless we have your authorisation.
Third party service providers.
We may share your personal information to help us operate, provide, improve, understand, customise, communicate, support, and market our Services. These third parties are contractually required to use it only to provide their service to us, and contractually barred from using it for their own purposes.
Securing your data
Grow Together will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. You acknowledge that the internet is inherently insecure, and we cannot guarantee security of data sent over the internet. Information relating to electronic transactions entered into via this website will be protected by encryption technology.
Updating this statement
Data Retention Policy
This policy was last updated: 31st May 2020 in accordance with the Data Protection Act (1998) and the General Data Protection Regulation (GDPR) on 25th May 2018.
Grow Together have created this policy to demonstrate its commitment to data security and the storage of data only for as long as is required.
Definition of "data"
For the purposes of this document, when we talk of “data” we refer to Parent/Legal Guardian data which has been inputted into Grow Together by the Parent or Legal Guardian wishing to book a class listed on Grow Together through the booking system.
Lastly we refer to Parent/Legal Guardian or Carer data which has been shared with us, with consent, by the participants who wish to receive our newsletter or emails.
Grow Together data is stored securely online using encryption.
Data retention periods
Grow Together commits to retain personal data only for as long as is necessary, which is a requirement of law. For accounting and tax purposes, we keep data for 7 years.
As "Data Controller", Grow Together is responsible for all the data it stores and has responsibility for keeping it secure. Grow Together has determined the following retention period:
Parents/Legal Guardians can upload their data to Grow Together through the booking system. While the Parent/Legal Guardian is actively attending classes, it will remain on the database.
If a Parent/Legal Guardian has not logged into the booking system within 7 years, they will be removed from the database (to comply with accounting and tax purposes).
If a Parent/Legal Guardian or Carer requests that Grow Together delete their data on their behalf at any time, these are actioned within 24 hours and all data relating to this customer is removed from all systems where it is stored with the exception of any payment records which need to be kept for 7 years.
Once data has been deleted, it cannot be retrieved
If you require any further information related to this policy, please contact Grow Together using the below contact details: Email: