Privacy Policy

Leadenham Military History Club

Privacy Policy – February 2025

This is the privacy policy of the Leadenham Military History Club. (‘the Club’, ‘we’, ‘our’, or ‘us’).

The Club can be contacted by email at milhistory@btinternet.com or by post c/o 53 High Street, Leadenham, Lincoln LN5 0PN

Introduction

This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

This notice applies to personal data collected through our website, through social media platforms and from you personally on applying for membership.

Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

Data Protection Officer

We have appointed a data protection officer (‘DPO’) who is responsible for ensuring that our privacy policy is followed.

If you have any questions about how we process your personal data, including any requests to exercise your legal rights, please contact our DPO, Tim Sisson at milhistory@btinternet.com.

Personal data we process

1.   How we obtain personal data

The only information we process about you is information that you have directly provided to us.

2.   Types of personal data we collect directly

When you join the Club, we ask you to provide personal data. This can be categorised into the following groups:

•     personal identifiers, such as your first and last names, your title and your date of birth

•     contact information, such as your email address, your telephone number and your postal address

•     records of communication between us including email messages and telephone conversations

We may also collect the above from you if you attend a meeting of the Club  as a guest, or by email in response to our publicity materials.

3.   Types of personal data we collect from third parties

We do not confirm the information you provide to us directly using data from other sources. Nor do we add to that information from other sources.

4.   Types of personal data we collect from your use of our services

By your using our website and our services, we may process:

•     your username and password and other information used to access our website and our services

•     information you contribute to our community, including reviews

•     your replies to polls and surveys

•     usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages

•     your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.

5.   Our use of aggregated information

We may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

For example, we may aggregate usage information to assess whether a feature of our website is useful.

However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.

6.   Special personal data

Special personal data is data about 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.

It also includes information about criminal convictions and offences.

We do not collect any special personal data about you.

7.   If you do not provide personal data we need

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract.

In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.

8.   The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.

If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

a. Information we process because we have a contractual obligation with you

When you join the club, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give us. Some of this information may be personal data.

We may use it in order to:

•     offer and sell Club products to you

•     notify you of the Club’s activities

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

b. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you ask us to provide you more information about the Club, you provide your consent to us to process information that may be personal data.

We will never pass your name and contact information to anyone else.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at milhistory@btinternet.com. However, if you do so, you may not be able to receive information from us about the Club’s activities.

We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.

c. Information we process for the purposes of legitimate interests

We may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

•     whether the same objective could be achieved through other means

•     whether processing (or not processing) might cause you harm

•     whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

•     improving our services

•     record-keeping for the proper and necessary administration of the Club

•     responding to unsolicited communication from you to which we believe you would expect a response

•     preventing fraudulent use of our services

d. Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal data.

e. Information we process to protect vital interests

In situations where processing personal information is necessary to protect someone’s life, where consent is unable to be given and where other lawful bases are not appropriate, we may process personal information on the basis of vital interests.

For example, we may inform relevant organisations if we have a safeguarding concern about a vulnerable person.

f. Information we process to protect the public interest

In situations where processing personal information is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, where consent is unable to be given and where other lawful bases are not appropriate, the controller may process personal information on the basis of vital interests.

Given that the Club is not a public authority, and given the extent of its activities, it is highly unlikely that we would ever process personal information on this basis.

How and when we process your personal data

9.   Your personal data is not shared

We do not share or disclose to a third party, any of your personal information that we have collected.

10. Payment information

Payment information is never taken by us or transferred to us either through our website or otherwise.

11. Direct Debit information

We do not operate Direct Debit arrangements.

12. Job application and employment

The Club is not an employer and operates solely through volunteers

13. Information obtained from third parties

Although we do not disclose your personal data to any third party, it is possible that we might receive data that is indirectly made up from your personal data from third parties whose services we use.

No such information is personally identifiable to you.

14. Third party advertising on our website

Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.

They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.

We do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy policy does not cover the information practices of these third parties.

15. Credit reference

To assist in combating fraud, we may share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

16. Disputes between users

In the event of a dispute between you and another user, provided that you consent, we may share your basic personal data, business information and contact information with the other user.

At our discretion, we may share other information to enable the dispute to be resolved through litigation or alternative dispute resolution methods.

Use of information we collect through automated systems

17. Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.

They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.

Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.

If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of our website.

The club’s website is hosted by Google and uses cookies from Google to deliver its services and analyze traffic. Information about your use of the website is shared with Google. By using the website, you agree to its use of cookies. The Club itself does not make any use of the information provided by the cookies placed by Google.

18. Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information such as your geographical location, your Internet service provider and your IP address. We also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

If combined with other information we know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

19. Re-marketing

We do not provide your personal data to advertisers or to third-party re-marketing service providers.

Other matters

20. Your rights

The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.

We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org

21. Use of our services by children

We do not sell products or provide services for purchase by children, nor do we market to children.

22. Delivery of services using third party communication software

With your consent, we may communicate using software provided by a third party such as Facebook (WhatsApp), Apple (Facetime), Microsoft (Skype) or Zoom Video Communications (Zoom).

Such methods of communication should secure your personal data using encryption and other technologies. The providers of such software should comply with all applicable privacy laws, rules, and regulations, including the GDPR.

If you have any concerns about using a particular software for communication, please tell us.

23. Data may be processed outside the UK

Our website is hosted in Google data centres around the world.

We may also use outsourced services in countries outside the UK from time to time in other aspects of our business.

Accordingly data obtained within the UK or any other country could be processed outside the UK.

We will use the following safeguards with respect to data transferred outside the UK:

•       the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority.

•     we comply with a code of conduct approved by a supervisory authority.

24. Control over your own information

It is important that the personal data we hold about you is accurate and up to date. Please inform us if your personal data changes.

At any time, you may contact us to request that we provide you with the personal data we hold about you.

When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information. Please be aware that we are not obliged by law to provide you with all personal data we hold about you, and that if we do provide you with information, the law allows us to charge for such provision if doing so incurs costs for us. After receiving your request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

If we delete your personal data at your request this limit the service we can provide to you.

We remind you that we are not obliged by law to delete your personal data or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.

25. Communicating with us

When you contact us by email, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our organisation.

We may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

26. Complaining

If you are not happy with our privacy policy, or if you have any complaint, then you should tell us.

When we receive a complaint, we record the information you have given to us on the basis of consent. We use that information to resolve your complaint.

If a complaint is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal data, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/ . We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

27. Retention period

Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:

•     to provide you with the services you have requested

•     to comply with other law

•     to support a claim or defence in court

28. Compliance with the law

Our privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).

29. Review of this privacy policy

We shall update this privacy policy from time to time as necessary.