Introduction

UnionCloud, the software which powers your students’ union/guild’s website (‘website’), is owned by OneVoice Digital Limited, which manages and operates the website on behalf of your students’ union. OneVoice takes your privacy seriously and is committed to protecting yours and your members’ personal data.  

In operating the website, we process your members’ personal data as a data processor on your instructions and in accordance with our agreement with you.  The terms of your privacy policy set out on your website will apply and should accurately describe your practices on data collection, use and sharing of personal information. You will be the controller of that personal data. We also set out below information about the data we collect on your behalf. 

In providing our services to you we may collect personal information about the user(s) operating the website and in this instance we are a data controller.

This Privacy Policy tells you the types of information we collect about you and the type of information we process about your members on your behalf when they visit the website, register with UnionCloud or which we otherwise obtain directly from you or from a third party, how we use that information, and the instances in which we share your information.  This Privacy Policy may change from time to time so please check this policy regularly.

The website is not intended for children and we do not knowingly collect data relating to children.

For the purposes of this Privacy Policy, the term “personal data” means any information which identifies you or your members or which allows you or your members to be identified when combined with other information.

Important information and who we are

Controller

OneVoice Digital Limited is the controller and responsible for your personal data, "OneVoice”, "we", "us" or "our" in this Privacy Policy.

We are part of the Arrk group of different legal entities, details of which can be found at section 5 of this Privacy Policy (“Arrk Group”).

If you have any questions in relation to this Privacy Policy or any requests to exercise your legal rights, please contact us at dpc@onevoicedigital.com

If you have any complaints about the way we use your personal data, please contact us so we can try to resolve the matter.  You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). 

Changes to the Privacy Policy and your personal data

This version was last updated on 14 November 2018.

It is important that the personal data we hold about you and your members is accurate and current, so please keep us informed if your personal data changes.

Third-party links

This 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 and your members. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the website, we would encourage you and your members to read the privacy policy of every website you visit.

The data we collect and/ or process about you and your members      

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

• Identity Data includes first name, last name, username or similar identifier, title, date of birth, gender.
• Contact Data includes address, hall of residence, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from your members and other details of products and services your members have purchased from us including the type of card used for a particular transaction (but not any other card details).
• Technical and Usage Data includes information about how you and your members access and use the website such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you and your members use to access the website, pages visited on the website and links followed.
• Profile Data includes usernames and passwords, purchases or orders, job title, name of employer, membership of clubs and societies, course details, interests, preferences, feedback and survey responses, nationality, domicile country and ethnicity.  
• Enrolment Data includes course name, enrolment date, name of educational institution, fee status, library card, department, Erasmus status, finalist, mode of study, placement, study type and additional identities
• Marketing and Communications Data includes preferences in receiving marketing from us and third parties, communication preferences and acceptance of terms and conditions.

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

We do not collect any Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

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

• Direct interactions. You or your members may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:
• request our products or services;
• create an account on the website;
• buy tickets for an event which we have publicised;
• complete a form on our website requesting us to contact you;
• subscribe to our publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey;
• make a complaint or give us some feedback.
• Automated technologies or interactions. As you or your members interact with the website, we may automatically collect Technical Data about yours or their equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you or them if you visit other websites employing our cookies. Please see our cookie policy at union_url/ get_cookie_policy_details for further details.
• Third parties or publicly available sources. We may receive personal data about you or your members from various third parties as set out below:
• Technical Data from the following parties:
  1. analytics providers;
  2. advertising networks; and
  3. search information providers.
• Contact, Profile and Enrolment Data from your university or college, and your students’ union.
• 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 availably sources such as the Electoral Register based inside the EU.

How we use your personal data

• 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 we have assessed that your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing personal data other than in relation to sending third party direct marketing communications via email or text message.  You and your members have the right to opt out of receiving marketing at any time by contacting us or by updating your marketing preferences on your profile page on the website at account/ profile>my details.

Purposes for which we will use your and your members’ personal data

We have set out below, in table format, a description of all the ways we plan to use yours and your members’ 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.

Note that we may process personal data for more than one lawful ground depending on the specific purpose for which we are using the data. Please contact us if you need details about the specific legal ground we are relying on to process the personal data where more than one ground has been set out in the table below. 

Marketing

We aim to provide you with choices regarding marketing and advertising and may use your or your members’ Identity, Contact, Profile and Technical and Usage Data to form a view on what we think you or your members may want or need, or what may be of interest. This is how we decide which products, services and offers may be relevant for you and your members.

You and your members will receive marketing communications from us or the NUS if you or they have requested information from us or the NUS through the website or purchased goods or services from us or if you or your members have provided us with your details when you entered a competition or registered for a promotion and, in each case, you or they have opted in to receiving that marketing.

Third-party marketing

We will get your or your members’ express opt-in consent before we share your or their personal data with any company outside the Arrk Group companies for marketing purposes.

Opting out

You and your members can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or your members or by contacting us at any time.

Cookies

The website uses cookies and similar technologies to distinguish you and your members from other users of the website. This helps us to provide you and your members with a good experience when you and they browse the website and allows us to improve the website. We may also use such technologies to track you and your members across the Internet and to display targeted advertisements to you and them on third party websites and social media platforms based on preferences and likely interests.  

You and your members can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you or they disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see union url/get_cookie_policy_details  

Disclosures of your personal data

We may share your and your members’ personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

• Other companies in the Arrk Group which currently is Arrk Limited (registered in England under number 03574335 whose registered office is at 196 Deansgate, Manchester, M3 3WF), OneVoice Digital Limited and Arrk Solutions Private Limited, a private limited company duly incorporated with registration number U72900MH2002FTC135091 under the laws of India, having its registered office at Unit No. 1 & 2, Building No. 5, Sector-2, Millennium Business Park, Mahape, Navi Mumbai, PIN 400710.  This Privacy Notice applies to each of those companies and we reserve the right to freely pass the data between these companies.   Arrk Limited (which is the parent company of OneVoice Digital Limited and Arrk Solutions Private Limited) and Arrk Solutions Private Limited have entered into a Model Form Contract based on the Standard Contractual Clauses on transfer of personal data to third countries as per Directive 95/46/EC of European Parliament and of the Council.   This allows for the lawful transfer of your data to Arrk Solutions Private Limited
• Our third party service providers who perform functions on our behalf in connection with the operation of our business such as IT service providers and system administrators, third parties who host and manage data, deliver our products and services, conduct reference and criminal records checks on candidates on our behalf etc.
• Professional advisers including lawyers, bankers, auditors and who provide consultancy, banking, legal, insurance and accounting services.
• Our third party advertising partners to advertise products to you and your members on third party sites which are tailored to meet your and their preferences and likely interests.
• Our third party analytics partners to analyse website traffic and understand customer needs and trends.  

• Third parties if we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our websites or customers.
• 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 and your members personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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.

Data retention

How long will you use my personal data for?

We will only retain your personal 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.

You can request details of retention periods for different aspects of your personal data by contacting us.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may 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.

Your legal rights

When you are located in the European Union you have the right to:

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 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on 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 (other than in the case of direct marketing).

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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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 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. 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.

If you wish to exercise any of the rights set out above, please contact us.

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.

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.

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.