Privacy Policy

1. Introduction

Welcome to The Truth Contract's privacy policy.

The Truth Contract is committed to protecting and respecting your privacy when you use our services, whether through our website https://thetruthcontract.co.uk, mobile application, membership platform, or otherwise (the “Services”).

This Policy (together with our Terms and Conditions of Use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. If we ask you to provide certain information by which you can be identified when using the Services, you can be assured that it will only be used in accordance with this Policy.

The Truth Contract respects your privacy and is committed to protecting your personal data. This privacy policy will inform you how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy

2. Important Information and Who We Are

Purpose of This Privacy Policy

This privacy policy aims to give you information on how The Truth Contract collects and processes your personal data through your use of the Services, including any data you may provide through this website, mobile application, or membership platform when you register or create an account to use the Services.

This website is not intended for children, and we do not knowingly collect data relating to children under the age of 16.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

The Truth Contract is the controller and responsible for your personal data (collectively referred to as "we," "us," or "our" in this privacy policy).

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact Details

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Truth Contract Limited
Web address: https://thetruthcontract.co.uk
Postal address: 21 Navigation Business Village, Navigation Way, Ashton-On-Ribble, Preston, Lancashire, England, PR2 2YP

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for 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.

Changes to the Privacy Policy and Your Duty to Inform Us of Changes

We keep our privacy policy under regular, annual review in December of each year.

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.

Third-Party Links

Our 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. When you leave our website, we encourage you to read the privacy policy of every website you visit.

3. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:

Identity Data: Includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.
Contact Data: Includes billing address, delivery address, email address, and telephone numbers.
Sensitive Personal Data: Includes ethnic identity, gender identity, sexual orientation, religion or faith, neurodivergence, mental health condition, disability, or another form of special category data.
Workstyle or Lifestyle Data: Includes working pattern, home status, tenure, socioeconomic factors, education level, and data that is not personally identifiable.
Financial Data: Includes bank account and payment card details.
Transaction Data: Includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, mobile phone vendor and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Profile Data: Includes your username and password, purchases made by you, your interests, employment status, place of work, salary, industry, profession, ethnicity, interests/hobbies, social media accounts, preferences, feedback, survey responses, and related profile data.
Usage Data: Includes information about how you use our Services.
Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or platform feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

If You Fail to Provide Personal Data

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 the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

4. How Your Personal Data Is Collected

We use different methods to collect data from and about you, including through:

Direct Interactions

You may give us your Identity, Contact, Sensitive Personal, Workstyle and Lifestyle, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

Apply for our services;
Create an account on our website, mobile application, or membership platform;
Subscribe to our service or publications, or respond to requests, prompts, or questions in the Services;
Request marketing to be sent to you;
Enter a competition, promotion, or survey; or
Give us feedback or contact us.

Automated Technologies or Interactions

As you interact with our Services, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. For further details, please see our Cookie Policy.

Third Parties or Publicly Available Sources

We will receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:
- Analytics providers such as Google, Apple, or Microsoft based outside the UK;
- Advertising networks; and
- Search information providers such as Google or Bing.
Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services.
Identity and Contact Data from data brokers or aggregators.
Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK

5. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
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 obligation.
Aggregated and anonymized for the purpose of market research.

Please view our glossary below to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on explicit consent as a legal basis for processing your personal data, although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for Which We Will Use Your Personal Data

We may use your personal data for the following purposes:

To register you as a new customer: We use your identity and contact data to perform the contract we have with you.
To process and deliver your order: This includes managing payments, fees, and charges, and collecting and recovering money owed to us. We use your identity, contact, financial, transaction, and marketing and communications data for this purpose. The lawful basis is the performance of a contract with you and our legitimate interest in recovering debts owed to us.
To deliver our goods and services to you: This includes providing V.I.P. (Voting Informed Patriot) Membership and M.A.D. (Make A Difference) Membership. We use your identity, contact, sensitive personal, workstyle and lifestyle, financial, transaction, and marketing and communications data. The lawful basis is the performance of a contract with you.
To manage our relationship with you: This includes notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey. We use your identity, contact, profile, and marketing and communications data. The lawful basis includes the performance of a contract with you, compliance with a legal obligation, and our legitimate interest in keeping our records updated and studying how customers use our services.
To enable you to partake in a prize draw, competition, or complete a survey: We use your identity, contact, profile, usage, and marketing and communications data. The lawful basis includes the performance of a contract with you and our legitimate interest in studying how customers use our services and growing our business.
To administer and protect our business and this website: This includes troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data. We use your identity, contact, and technical data. The lawful basis includes our legitimate interest in running our business, providing administration and IT services, ensuring network security, and complying with legal obligations.
To deliver relevant website content and advertisements: This includes measuring or understanding the effectiveness of the advertising we serve. We use your identity, contact, profile, usage, marketing and communications, and technical data. The lawful basis is our legitimate interest in studying how customers use our services, growing our business, and informing our marketing strategy.
To use data analytics to improve our website and services: This includes improving our products, marketing, customer relationships, and experiences. We use your technical and usage data. The lawful basis is our legitimate interest in keeping our website relevant, developing our business, and informing our marketing strategy.
To make suggestions and recommendations to you: This includes goods or services that may be of interest to you. We use your identity, contact, technical, usage, profile, and marketing and communications data. The lawful basis is our legitimate interest in developing our products and growing our business.

6. Disclosures of Your Personal Data

We may share your personal data with the parties set out below for the purposes mentioned in this privacy policy:

Internal Third Parties: For details, see our Sub-Processor Policy.
External Third Parties: For details, see our Sub-Processor Policy.
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 policy.

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 specified purposes and in accordance with our instructions. Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information.

Our appointed data processors include:[add Macklin’s details and any other?

Appointed Data Processors

Our carefully selected partners and service providers may process personal information about you on our behalf. This includes, but is not limited to:

Digital Marketing Service Providers: We periodically appoint digital marketing agents to conduct marketing activity on our behalf, which may involve the compliant processing of personal information.
Appointed data processors such as Macklin and any other relevant providers (details to be updated as necessary).

7. International Transfers

Many of our external third parties are based outside the UK, so their processing of your personal data will involve a transfer of data outside the UK.

For further details, please refer to our Sub-Processor Policy.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

Ensuring the country has been deemed to provide an adequate level of protection for personal data by relevant authorities.
Using specific contracts approved for use in the UK, which give personal data similar protection to what it has under UK law.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK.

8. Data Security

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized 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 are subject to a duty of confidentiality.

We have also 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

How Long Will You Use My Personal Data For?

We will only retain your personally identifiable data for as long as reasonably necessary to fulfill the purposes we collected it for, including satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you, or to aggregate and anonymize it as part of wider market research.

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 unauthorized 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.
The applicable legal, regulatory, tax, accounting, or other requirements.

Your Right to Request Deletion

In some circumstances, you can ask us to delete your data. Details on how to make such a request can be found in:

Our Data Retention Policy.
Our Data Subject Access Request Process.

10. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include the following:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and 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, although we may need to verify the accuracy of the new data you provide.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your data where you have successfully exercised your right to object to processing, 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) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in 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.
- You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or a third party. We will provide 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 that 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. 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.

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 could refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help 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 for further information in relation to your request to speed up our response.

Time Limit to Respond

We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.

11. Glossary

Lawful Basis

Legitimate Interest: This means the interest of our business in conducting and managing our business to enable us to provide you with the best service/product and the most secure experience. We ensure 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 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.
Performance of Contract: This means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a Legal Obligation: This means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third Parties

Third Parties include, but are not limited to:

Service providers acting as processors 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 who require reporting of processing activities in certain circumstances.

Your Legal Rights

You have the following rights under data protection laws:

Request access to your personal data: Enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.
Request correction of the personal data we hold about you: Enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data provided.
Request erasure of your personal data: Enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. This right also applies where you have successfully exercised your right to object to processing, where we have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you at the time of your request.
Object to processing of your personal data: You can object where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate compelling legitimate grounds to process your information, which override your rights and freedoms.
Request restriction of processing of your personal data: Enables you to ask us to suspend processing your personal data in certain scenarios, such as when you contest its accuracy or object to its processing.
Request the transfer of your personal data: Enables you to request the transfer of your personal data to you or a third party in a structured, commonly used, machine-readable format.
Withdraw consent: You can withdraw consent at any time where we are relying on it to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. However, withdrawing consent may impact our ability to provide certain products or services to you.

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