Privacy Policy


1 Introduction

1.1 she can play ltd, its subsidiaries and all affiliated entities (“we”, “us”, or “our”) are committed to respecting and protecting your privacy. This Privacy Policy (the “Policy”) explains how we will collect, store and use any personal data you provide via our website, email or networking with our people and when you otherwise communicate with us.
1.2 Our details are as follows:
• Data controller: 45 OAKLEY CLOSE , GRAYS, Grays, RM20 4AN, United Kingdom
1.3 This Policy may change from time to time and, if it does, the up-to-date version will always be available on our website and becomes effective immediately.
1.4 Please take the time to read this Policy, which contains important information about the way in which we process personal data.
1.5 For the purposes of this Policy, “European Data Protection Legislation” is defined as, for the periods in which they are in force, the European Data Protection Directive 95/46/EC, all laws giving effect or purporting to give effect to the European Data Protection Directive 95/46/EC (such as the Data Protection Act 1998) or otherwise relating to data protection (to the extent the same apply) and, from 25 May 2018, the General Data Protection Regulation (Regulation (EU) 2016/670) (“GDPR”) or any equivalent legislation amending, supplementing or replacing the GDPR.

2 Information we may collect about you

2.1 We may collect and process information about you and your personnel through various means, including:
• in the course of carrying out work for you (or your business)
• via our website (e.g. on our ‘Contact Us’ page or our news and insight subscription form, submitting a job application etc.)
• by email or other electronic correspondence
• by telephone
• networking
• otherwise through providing our services or operating our business.
2.2 The personal data you give to us may include:
• your name and title
• contact information, medical information, including telephone number, postal address and email address
• information relating to your location, preferences and / or interests
• employment and job application details, e.g. date of birth, employment history, qualifications, equality monitoring information
• photographic identification and video footage
• in certain circumstances, your and others’ signature(s), National Insurance number(s), financial details such as bank account details and details of any relevant sanctions or similar restrictions
• in certain circumstances, data relating to health (including disabilities)
• the content of any enquiry submitted over our website
• any other personal data we collect (such as the client reference number which may be assigned to you) in the context of our work for our customers or in the course of operating our business.
2.3 Each time you visit our website, we may automatically collect the following information:
• Web usage information (e.g. IP address), your login information, browser type and version, time zone setting, operating system and platform.
• Information about your visit, including the full Uniform Resource Locators (URLs) clickstream to, through and from our website (including date and time); time on page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs).
• Location, device and demographic information (Google Analytics provides age range and gender information. Find out more about how Google collects demographic data).
2.4 We may ask you for information when you report a problem with our website.
2.5 If you contact us, we may keep a record of that correspondence.
2.6 The personal data described above may relate to any of the following categories of person:
• our customers and customers’ personnel
• our prospective employees, work experience students or other job applicants
• those emergency contacts whose details have been provided to us by our people
• our prospective target customers
• our contractors and suppliers
• those who submit enquiries through our website
• any other visitor to our centres.

3 Cookie Policy

3.1 Our website uses cookies to distinguish you from other users, to improve your experience on our website, and, to recommend content that may be of interest to you.
3.2 This Cookie Policy explains how we use cookies, why and how this improves our service to you. It also sets out how you can manage your cookies.
3.3 By visiting our website you are accepting and consenting to the practices described in this Cookie Policy.
3.4 We reserve the right to make changes to this Cookie Policy at any time. This Policy may change from time to time and, if it does, the up-to-date version will always be available on our website and becomes effective immediately. Your continued use of our website is taken as meaning that you agree to any such changes.
3.5 Cookies help us to distinguish you from other users and to see how you interact with our website. This information can help us to improve our website and surface website content based on your previous browsing behaviour.
3.6 We use the following types of cookies:
3.6.1 Analytical and performance cookies.
We may use analytics service providers for website traffic analysis and reporting. These providers use cookies to generate statistical and other information about how you use our website. The analytics generated include the number of visitors to the site, how long they stay and how they navigate the site. This helps us to improve the way our website works. The analytics generated may be used to create reports about the use of our site and the analytics service provider will also store this information.
3.6.2 Advertising and targeting cookies.
We may use cookies such as the Google AdWords tracking cookie to advertise online. This cookie uses information about you and your browsing behaviour on our site to serve relevant adverts across the Google Display Network. You can opt out of Google’s AdWords cookies at any time by changing your preferences in Google’s Ad settings.
3.6.3 Functional cookies.
We may use functional cookies that remember choices you have made when browsing our site. We are then able to provide a more personalised and enhanced user experience by delivering content related to your interests.
3.6.4 Strictly necessary cookies.
These cookies are required for the administration and operation of our website. Some cookies that we use are necessary for our site to function properly and to enable you to navigate and use its features.
3.6.5 Third party cookies
Third party cookies are cookies that exist on our website but originate from different domains. For example, we encourage visitors to share our content on various social networks. We add buttons to allow people to share easily to those networks. When we include these social ‘plugins’, it gives those sites the flexibility to use cookies. They can’t read any cookies we set from our website, and we can’t read any cookies they set.
Other websites and services (e.g. advertising networks, web traffic analysis services and content recommendation engines) may also use cookies. We have no control over these cookies and you can find out more about them by checking the third party providers’ websites. These cookies are likely to be analytical/performance cookies or targeting cookies.

3.7 Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, email address, and phone number. We refer to this information as “Order Information”. 
3.8 If you continue to browse our website we will assume that you are happy to receive all cookies from the site. To opt out of cookies, you can change the settings on your internet browser. For more information please consult the “Help” section of your browser or visit www.aboutcookies.org or www.allaboutcookies.org. Please note that if you do set your browser to reject cookies, you may not be able to use all of the features of our website.

4 How we will use your information

4.1 We may use your information for the following purposes:
a) to respond to any query that you may submit to us
b) to manage our relationship with you (and/or your business), including by maintaining our database of customers and other third parties for administration, and accounting and relationship management purposes
c) to complete any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations).
d) to carry out any relevant conflict checks
e) to send you any relevant information on our services and events that may be of interest to you using the email and/or postal address which you have provided, but only if you have given us your consent to do so or we are otherwise able to do so in accordance with applicable European Data Protection Legislation
f) to process any job application you (or your representative) has submitted
g) to ensure that our website’s content is presented in the most effective manner for you and your device
h) to customise our website according to your interests
i) to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey responses
j) to allow you to participate in interactive features on our website when you choose to do so
k) as part of our efforts to keep our website safe and secure
l) to measure or understand the effectiveness of advertising we send to you and others, and to deliver relevant advertising to you
m) to comply with any other professional, legal and regulatory obligations which apply to us or policies that we have in place
n) as we feel is necessary to prevent illegal activity or to protect our interests.

5 Sharing your information

5.1 We may share your details with carefully selected third parties. These may include service providers, support services and organisations that help us to market or implement our services and third parties instructed to enable us to fulfil our contractual obligations to you and/or our customers in the course of business. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. 
5.2 If we share your information with third parties they will process your information as either a data controller or as our data processor and this will depend on the purposes of our sharing your personal data. We will only share your personal data in compliance with the European Data Protection Legislation.
5.3 We may disclose your information to third parties when:
• you specifically request this or it is necessary to provide our services to you
• if our website or substantially all of its assets are acquired by a regulated third party, in which case personal data held by it about its customers will be one of the transferred assets
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property or safety of our website, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5.4 The third parties include:
• our bank
• our insurers
• our auditors, including external accreditation bodies
• other professional advisors or third parties (including counsel, consultants, accountants) with whom we engage as part of our work for our customers or who our customers separately engage in the same context
• our data processors providing catering, security, email security, data governance, archiving and other IT and business support services
• our email marketing platform provider and our website platform provider
• selected partner digital agencies and online job application provider
• analytics and search engine providers that assist us in the improvement and optimisation of our website
• any third party you ask us to share your data with.
5.4 Our website may, from time to time, contain links to and from the websites of advertisers and partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
5.5 We will not rent or sell our users’ or other contacts’ details to any other organisation or individual.

6 Storage and retention of your personal data

6.1 We follow strict security procedures as to how your personal information is stored and used, and who sees it, to help stop any unauthorised person getting hold of it. All personal information you register on our website will be located behind a firewall. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure and although we do our best to protect your personal data, we cannot absolutely guarantee the security of your data.
6.2 We will keep your information stored on our systems for as long as it takes to provide the services to you. We may keep your data for longer than our stated retention period if we cannot delete it for legal, regulatory or technical reasons. We may also keep it for research or statistical purposes. If we do, we will ensure that appropriate safeguards are in place to protect your privacy and only used for those purposes.
6.3 Any contact details stored on our client relationship management database will be removed from our mailing lists if they do not interact with our emails (i.e. open emails or click on links within them) for a certain period following which they will be moved to an archive folder before being deleted permanently.
6.4 The third parties we engage to provide services on our behalf will keep your data stored on their systems for as long as is necessary to provide the services to you.

6.5 we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work. 

You can opt out of targeted advertising by using the links below: 
- Facebook: https://www.facebook.com/settings/?tab=ads 
- Google: https://www.google.com/settings/ads/anonymous 
- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads 

6.6 We will, subject to paragraph 6.2, not store your information for longer than is reasonably necessary or required by law.

7 Sending your information outside of the EEA

7.1 If we need to share your personal data with a recipient outside the European Economic Area (“EEA”) we will ensure we do so in compliance with European Data Protection Legislation, including where applicable by ensuring that the transfer is necessary to perform a contract in place with you or a contract entered into in your interests.
7.2 Our people may access our systems remotely when working abroad (including from jurisdictions outside the European Economic Area). Where they do so, they are required to use our systems and access any personal data in accordance with all the usual policies and procedures.

7.3 If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below. 

7.4 In addition, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States. 

8 Withdrawal of consent

8.1 Where we process your personal data we do so on the basis that you have provided your consent for us to do so for the purposes set out in this Policy when you submitted your personal data to us. You may withdraw your consent to this processing at any time by contacting us at info@shecanplay.uk or via the web form on our contact page.
8.2 If you do withdraw your consent, we may still be able to process some of the data that you have provided to us on other grounds and will notify you of these at such time.

9 Your information rights

9.1 European Data Protection Legislation gives you the right to access information held about you. You are entitled to be told by us whether we or someone else on our behalf is processing your personal information; what personal information we hold; details of the purposes for the processing of your personal information; and details of any third party with whom your personal information has been shared.
9.2 You can access the personal information we hold on you by writing to us at: FAO: Data Protection Officer, 45 OAKLEY CLOSE , GRAYS, Grays, RM20 4AN, United Kingdom. You can also contact us by email at info@shecanplay.ukor by completing our web form via our contact us page.
9.3 We will ask you to provide original proof of identity before we show you your personal information – this is so we can prevent unauthorised access.

9.4 You have the additional rights to request rectification and erasure of your personal data and to request restriction of, and to otherwise object to, our processing of your personal data and you can exercise these rights at any time by contacting info@shecanplay.ukor by completing our web form via our contact us page.
9.5 From 25 May 2018, you will also be entitled to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format, and to transmit that data to another data controller. You can exercise this right from 25 May 2018 by contacting us at info@shecanplay.ukor by completing our web form via our contact us page.

10 Complaints

10.1 If you consent to us contacting you, we will always aim to be respectful, relevant and appropriate. If at any time you do not think that we have complied with this, please contact us straight away to let us know.
10.2 You also have the right to make a complaint to the Information Commissioner’s Office. For more details please visit the ICO website.

11 Contact Us

Questions, comments and requests regarding this Policy should be addressed to our Data Protection Officer:
45 OAKLEY CLOSE , GRAYS, Grays, RM20 4AN, United Kingdom
Telephone number: +44 (0) 7917428895


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