DATE OF POSTING: 16 April 2018

Welcome to www.encorum.co.uk (‘the Site’), which is owned and operated by Silver Sparkle Ltd (‘we’, ‘us’, ‘our’, as applicable). We are committed to protecting and respecting your privacy and have recently reviewed and updated our procedures in accordance with the EU General Data Protection Regulations (“GDPR”) which come into effect on 25 May 2018. This notice (together with the Terms and Conditions, Cookie Policy and any other documents we refer to in this notice or those Terms and Conditions) set out how we will use your personal information and with whom it will be shared. Please read the following carefully.

Please refer to our Cookie Policy if you would like detailed information on the types of cookies we use on the Site, the purposes for which we use each cookie, how you can disable and enable the use of certain cookies and the consequences of doing so.

Please note that by visiting and using the Site you are agreeing to the use of your personal information in the way that is described in this Privacy Notice.

If you have any queries or concerns regarding this Privacy Notice, please contact us at security@encorum.co.uk.

Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email.

What information do we collect about you?

    1. We may collect and process the following data about you (‘your information’):
      1. information that you submit online via our Site, including your name, address and e-mail address. (Please note that we do not request any financial information, and we do not request telephone contact details);
      2. any correspondence you send to us;
      3. details of your visits to the Site and the resources that you access (which may include, amongst other things, traffic data and communication data);
    2. We are aware that your information may be confidential and we will protect the confidentiality of your information in accordance with our normal procedures and legal requirements.

How will we use your information?

    1. We use your information in the following ways:
      1. to mail you a personalised welcome letter if you have provided a UK address when registering. Thereafter we will not send anything to your address except with your prior consent, and the only record of your address is held within the website (see Section 16 – “How do we keep your information secure”.)
      2. to ensure that the Site’s content is presented as effectively as possible for you;
      3. to ensure that the activities and events we recommend to you through your membership are relevant to you and your location;
      4. for our internal purposes, such as quality control, site performance, system administration and to evaluate use of the Site, so that we can provide you with enhanced services;
      5. to notify you about changes to our services;
      6. to provide you with information, products or services that you request from us, or which we feel may interest you (provided of course that you agree);
      7. to create reports to assist with future marketing; and
      8. to enable you to participate in the features of the Site, when you choose to do so.
    2. We may monitor your use of the Site and record your email address to report aggregate information to our advertisers.  This is statistical information about our users’ browsing actions and patterns and does not identify any individual. 
    3. We collect non-personal aggregated statistics data about visitors to the Site and traffic patterns using Google Analytics.  Just to be clear, this information does not identify users in any personal capacity and we do not use this information to build profiles on individual users: it just contains generalised information about the users of the Site. Google is in the process of further enhancing its controls in this area and we will be reviewing and implementing these as we see appropriate
    4. We only keep your information for as long as is necessary. Back up records of historic personal information is retained by our server host, Cloudabove (see Sections 12 & 17) for 14 days then deleted. Google Analytics now allows us to ensure data is not held by them indefinitely and we will be implementing specific retention periods.

Cookies

    1. We may use ‘cookies’ to collect the information referred to and track your use of the Site. Cookies are small data files which gather information about your use of the Site and help us to provide you with a good experience when you browse the Site.  For more information about ‘cookies’, why we use them and how to refuse cookies, please see our Cookie Policy.

Marketing

    1. If you are an existing member or have expressly indicated that you have an interest in being a member with us, with your consent we may contact you by email with information about products and services which are similar to those you have purchased or in which you have expressed an interest. We are aware that many sites send a high volume of such marketing e-mails, whereas we respect your right to privacy and therefore typically send a newsletter once every few weeks.
    2. We will not contact you in this way, if you have not ticked the relevant box during the registration process when we collect your information, or subsequently given your explicit consent to be contacted. You may also ask us at any time to remove your details from any such contact list by contacting us at contact@encorum.co.uk.
    3. We do not buy member lists from third parties, and we do share or sell member lists with or to any third parties.

Where do we transfer your information?

    1. We do not transfer your information anywhere. It is stored within the website on secure servers operated by Cloudabove (www.cloudabove.co.uk) in London & Manchester, in the UK.

With whom do we share your information?

    1. We do not share your information with other organisations, other than:
      1. if we, or substantially all of our company assets are acquired by another party, or another party agrees to acquire Encorum.co.uk, in which case your information will be one of the transferred assets;
      2. with business partners, suppliers, sub-contractors for the performance of any contract we enter with them or you; and
      3. if we have to share your information to comply with legal or regulatory requirements, or if we have to enforce or apply our Terms and Conditions or any other agreements or to protect our rights, property or our customers, etc. This may involve exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
    2. We may share the non-personal aggregated statistics data about visitors to the Site with third parties.
    3. We do not pass your email address to selected third parties (as described in Section 12.2 above) unless you have explicitly consented to this.
    4. We do not send any personal information that we collect about you on the Site to any social media sites that you link to your account, e.g. Facebook, nor do we share that information with such sites.We do not collect any personal information about you from those sites.

How do we keep your information secure?

    1. All your information is stored on secure servers in the UK operated by Cloudabove (www.cloudabove.co.uk). Any actions you perform on the site which are related to your account will be encrypted. If you have a username, password or other login details which enable you to access certain parts of the Site, you must not allow any other person to use them and must treat them as confidential. If you believe or suspect that someone else knows your login details you must contact us at security@encorum.co.uk as soon as possible. Please also see our Terms and Conditions.
    2. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will apply our normal procedures and comply with legal requirements to protect your information, we cannot guarantee the security of your information transmitted to the Site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
    3. The Site may from time to time contain links to and from other websites.  If you follow a link to any of those sites, please note that those sites ought to have their own privacy policies and that we do not accept any responsibility or liability for those sites or for their privacy policies. Please check those privacy policies before you submit your information to those sites. Please also see our Terms and Conditions for further provisions relating to other websites.

Third party payment processors

    1. Membership is free so we do not ask for, or take, any financial information from you as part of the registration process. In the event that you purchased a product directly from us, we would use PayPal or iZettle to process your payment.PayPal operates a secure server to process your payment details. They encrypt your credit or debit card information and authorise payment directly. This means that your credit card or debit card details are never revealed to us. Please read their privacy policy at https://www.paypal.com/uk/webapps/mpp/ua/privacy-full to see what security measures they have in place and how they treat your information. Similarly iZettle, whom we use for point of sales (“POS”) card purchases use cryptographic servers to ensure that when processing a purchase using a debit or credit card your details are fully encrypted . Further details about iZettle can be found at www.izettle.com along with their privacy policy and security features.

Purchasing goods and services from third parties using your membership

    1. Your membership will provide you with access to links from which you may purchase goods and services from third parties.If you do make a purchase using these links, the information you provide is transmitted directly to the relevant third party retailer and not to us.Consequently, that information is processed in accordance with the relevant retailer’s privacy policy and other terms and conditions and not our own. Please read the relevant retailer’s privacy policy and terms carefully before providing your information or placing an order with a third party retailer.

Your rights

Under the GDPR you have various individual rights, each of which we address below. If you wish to read more about your rights in respect of your personal data we recommend visiting the UK Information Commissioner’s Office website at ico.org.uk

    1. the right to be informed – You can view our Privacy Notice, Terms & Conditions, and Cookie Policy on our website at any time,
    2. the right of access – you have the right to see the personal information that we hold about you, whether collected through your use of the Site or through any communications that you have had with us. You have the right to access your information and should direct any request for your information to us at security@encorum.co.uk.Please note that currently a fee of ten pounds sterling (£10.00) may be payable to meet our costs in providing you with details of the information we hold about you,
    3. the right of rectification – You have the right to rectify your information by sending a written request to us at contact@encorum.co.uk. You can access and rectify certain parts of your personal information by logging into your member’s account at any time,
    4. rights in relation to prior consultation – you have rights to give your prior consent before your personal information is used or retained in certain ways. We address this by now seeking your specific “opt-in” consent at the time of registration, including “Opt-in” & Opt-out” boxes in the Member’s area and, specifically in the period prior to EU GDPR coming into effect, contacting existing members by e-mail seeking their consent,
    5. the right to restrict processing – You have the right to assume we will not process your information (or pass your information to other companies or organisations) for marketing purposes unless you have given your specific consent. If you wish you can tick the appropriate box on the registration form just to receive our newsletters. You can change this at any time by contacting us at contact@encorum.co.uk. We have carefully reviewed our own procedures to ensure that we request the minimum personal information that we require to operate Encorum and that this is fair, reasonable and appropriate,
    6. the right to object to processing including profiling – You have the right to object to mass processing of your data and potential scoring or profiling. We confirm that we do undertake mass processing of personal data, that we don’t do any scoring, and we don’t do any profiling other than note your selected interests and your town & county where you live,
    7. the right of erasure/the right to be forgotten – You have the right to cancel your membership at any time. Once notified we will then delete your membership profile. As noted in Section 6, backup records of our website data are retained for 14 days by Cloudabove then deleted, and Google Analytics has introduced the ability to select specific retention periods which we will be implementing,
    8. the right to data portability – in the event that Encorum offered the capability to store significant personal information on the site or a unique identification number that gave you access to a secure third party network, you have the right to have that data transferred to another provider. As Encorum does not have such capability and you membership number is only used for identifying you within Encorum, we believe this does not apply here,
    9. rights in relation to international transfer – you have the right to have to give your specific consent before your data may be transferred to other countries not previously agreed to. All Encorum data is currently held in the UK only,
    10. rights in relation to automated decision-making – you have the right to receive details as to how automated decision-making is being applied in evaluating your suitability for certain products or services. No automated decision-making is used with Encorum,
    11. If you have a complaint about how we have used your information, you have the right to complain to the Information Commissioner’s Office (“ICO”).

Changes

    1. We may make changes to this Privacy Notice at any time by sending you an email with the modified terms or by posting a copy of them on the Site.  Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on the Site, whichever is the earlier.Your continued use of the Site after that period expires means that you agree to be bound by the modified policy.

How to contact us

  1. Questions, comments or requests concerning this Privacy Notice are welcomed and should be addressed to us at contact@encorum.co.uk.
  2. The Site is owned by Silver Sparkle Ltd, a company incorporated in England. The registered office address is James Cowper Kreston, Mill House, Overbridge Square, Hambridge Lane, Newbury, Berkshire, England, RG14 5UX and our registered company number is 09932492.