Privacy, Data Protection & Data Retention Policy

Little Wickets is committed to ensuring that your privacy is protected and that we comply with all current data protection legislation as a data controller and processor.  Should we ask you to provide certain information by which you or children,within your legal care, can be identified you can be assured that it will only be used and protected in accordance with this policy. This privacy, data protection & data retention policy sets out how the Little Wickets Group uses and protects any identifiable personal information.

Little Wickets may change this policy by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 17/05/2018 and is in compliance with the EU General Data Protection Regulation that come into effect on 25/05/2018

1. Introduction

The Little Wickets Group includes the UK registered companies Little Wickets Ltd (Company Number 7231483) & Little Wickets (East Midlands) Ltd (Company Number 7043892). Little Wickets (East Midlands) Ltd is a wholly owned subsidiary of Little Wickets Ltd. For the purposes of clarity this privacy policy applies to both companies and their associated website (www.littlewickets.com) and uses the name Little Wickets to refer to the Little Wickets Group of companies as a whole.

The registered address for Little Wickets Group of companies is Cawley House, 149-155 Canal Street, Nottingham, Nottinghamshire NG1 7HR.

Little Wickets Ltd is registered with the Information Commissioner’s Office www.ico.org.uk (ICO Reference no A1040147). The Data Protection Officer is Chloe Williams, who may be contacted in writing to our registered address (Cawley House, 149-155 Canal Street, Nottingham, Nottinghamshire NG1 7HR) or via email (chloe@littlewickets.com).

 

2. What Data do we collect about you and your child(ren)

Any personal information which you provide to us and any information, from which we can identify you, is held in accordance with the registration we have with the Data Commissioner’s Office.

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

  • Identity Data may include yours or your child(ren)’s first name, maiden name, last name, username, marital status, title, date of birth and gender.
  • Contact Data may include your home address, personal & work email addresses and telephone numbers.
  • Financial Data may include your bank account and payment card details.
  • Transaction Data may include details about payments between us and other details of purchases made by you.
  • Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site and our mobile app.
  • Profile Data may include your username and password, purchases or orders, your location, your interests, preferences, feedback and survey responses.
  • Usage Data may include information about how you use our website, mobile app, products and services.
  • Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your preferred communication method. You will be asked separately for your consent to opt-in to receive Marketing information.
  • We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. For example, if we review your Usage Data to work out the percentage of website users using a specific feature of our site. However, if we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

3. What we use personal data for

We hold your personal information under the lawful basis for processing of legitimate interests i.e. the processing is necessary for our legitimate interests and running the Little Wickets business or the legitimate interests of a third party contracted partner unless there is a good reason to protect the individual’s personal information which overrides those legitimate interests.

We may use yours and your child(ren)s personal date for;

  • Internal record keeping to administer our obligations to fulfil delivery of Little Wickets products, services and activities.
  • To allow third party contracted suppliers to deliver products, services and activities on Little Wickets’ behalf.
  • To communicate with you about Little Wickets products, services & activities
  • To obtain feedback on Little Wickets’ current products, services & activities
  • Market research to assist us in developing new & existing services & activities
  • To instigate improvements to & increase Little Wickets’ range of products, services & activities
  • To ensure Child Welfare, Safeguarding & Safety legislation is adhered to
  • To provide you with Little Wickets product, services & activity availability, information, news, updates,
  • Send timely and relevant reminders
  • To update you on our policies & procedures
  • To customise the Little Wickets website & App according to your stated preferences & interest
  • If you consent, to send you Marketing Messages- see Paragraph 9 below

We may contact you by email, phone, in person, social media messaging, SMS messaging services, App Alerts or post.

4. Collecting Sensitive Data as defined by the ICO

Please refer to this link for the definition of ‘Sensitive Data’

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/key-definitions/

Under current data protection regulations Little Wickets collect some information about children attending our activities, which falls into the category of ‘Sensitive Data’. Parents are requested to inform us specifically of any medical, physical, behavioural, mental health or other issue that may affect a child’s ability to participate in Little Wickets activities.

Little Wickets require the parent/carer’s explicit consent to process & handle ‘sensitive data’, You will be asked to confirm you are a child’s legal guardian & as such to consent to this data processing as part of the initial ‘parental consent’ process, when you register your interest in and/or booking Little Wickets services & activities. If you do not provide us with your consent to process that data when requested, we may not be able to allow a child to attend Little Wickets activities.

5. What we use ’Sensitive Data’ for;

  • We use this information to ensure that the Little Wickets’ activities are appropriate for each individual child’s circumstances.
  • We may share this information with the relevant contracted third parties & team members to ensure they can deliver a specific service or activity appropriately and safely.
  • To support the child’s participation in Little Wickets activities.
  • To protect the vital interest of the child(ren) (& adults) attending Little Wickets’ activities
  • Ensure official Child Welfare, Safeguarding & Safety legislation and guidance is followed

Based on the information provided Little Wickets reserves the right not to offer our services or activities to individual children.

6. Disclosure of yours and/or your child(ren)’s personal data

Where possible personal data will be anonymised However in certain circumstances we may have to share your personal data with the parties listed below for the purposes set out in the table in paragraphs 3 & 5 above:

  • Service providers 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 based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.
    We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
  • Police or any other regulatory or government authority investigating suspected illegal activities, safeguarding or child welfare matters where this is required and permitted by law. We may process your personal data without your knowledge or consent if we are legally requested to do so by legitimate authorities.

7.  How we collect yours & your child(ren)’s personal data

We collect data about you through a variety of different methods including:

Direct interactions: You may provide data by filling in forms on our website, our mobile app or by communicating with us in person, by post, phone, email, via social media messaging & comments or otherwise, including when you:

  • register your interest in Little Wickets products or services
  • create an account on our site or mobile app
  • subscribe to our, newsletter, services or publications
  • request resources or marketing be sent to you
  • enter a competition, prize draw, promotion or survey
  • feedback surveys
  • Complete a form at a promotional event

Automated technologies or interactions: As you use our site, or mobile app we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. For further details please see our cookie policy at https://www.littlewickets.com/cookies/

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties including but not limited to Facebook, Instagram, Twitter, Google Analytics
• analytics providers such as Google based outside the EU;
• advertising networks (such as Mum and Working and Total Franchise if you are enquiring about a franchise) based inside the EU; and
• search information providers such as but not limited to All4kids, Whatson4 kids, Netmums, Mumsnet, Hoop, & ClubHub based inside the EU

Booking engines such as but not limited to Hoop, ClubHub & Class4Kids where a booking is made for a Little Wickets activity.

Franchise recruitment agencies

Information from schools/nursery regarding session within that school / nursery, other organisations such as sessions requested within the community, promotional events such as school fairs & community event and birthday party registration forms.

8. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at info@littlewickets.com

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

9.  Marketing

We would like to keep you up to date with relevant Little Wickets’ offers, products and services and those from selected third parties. If you choose to opt-in to receiving Marketing information, Little Wickets will send you marketing messages but we will not share your personal information with any other external third party, without your direct consent an opt-in process. Your personal information will remain under our control and we will use it to generate recommendations.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at info@littlewickets.com at any time.

If you choose to opt-out of receiving marketing messages, Little Wickets will be restricted from using your personal information to make personalised recommendations to you. You may still see offers and information on the Little Wickets website & mobile app, but the contents will not be personalised in any way and we cannot guarantee its relevance.

Where you opt out of receiving Little Wickets’ marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Little Wickets are unable to prevent third party contracted suppliers or providers from using personal information which you have otherwise provided to them for marketing purposes.

10. Third Party Suppliers Data Controllers & Processors

Little Wickets use a number of third party providers to for record keeping, to deliver, to communicate, process and manage Little Wickets’ products, activities and services.  We have contractual service user agreements with following third party providers, which include a requirement that both parties comply with current UK & EU data protection legislation, whether they are based in the UK or not.

Little Wickets is reliant upon the individual third-party’s full disclosure to be able to keep you updated. If we are made aware of any breaches, changes or issues that would affect individual’s rights with regard to the data contracted third-party hold, supply or have access to we will follow the procedures outlined in paragraph 13 below regarding Data Security, in line with the prevailing legislation.Some third party suppliers will be acting as joint data controllers and processors with Little Wickets and will hold your data to enable them to deliver Little Wickets’ service requirements. We regularly check that our 3rd party suppliers’ contracts & terms are compliant with current legislation.

Third party suppliers and providers may also independently request permission to use & hold your data for marketing purposes. We would urge you to check their individual Privacy and Data Retention policies before opting in.

11. Little Wickets’ contracted Booking & Activity Management Platform- ClassForKids Ltd

ClassForKids is a Joint Data Controller & Data Processor of the personal data collected by and on behalf of Little Wickets. Class4Kids Ltd, is a company incorporated in Scotland (Company Number SC458210)

ClassForKids (www.classforkids.co.uk) is an online platform offering information and listings for events, classes, activities and groups for children and they provide Little Wickets’ with a coud-based online booking & activity management tool. Individuals can register their interest in, request information about and book online for Little Wickets activities through the ClassForKids Little Wickets Booking page (https://littlewickets.class4kids.co.uk/) or they can  contact Little Wickets direct via phone, email, text messaging or social media channels.

All Little Wickets’ customer data (whether provided direct to Little Wickets or through the online Class4Kids booking platform) is loaded onto the Little Wickets ClassForKids cloud-based  online platform (https://littlewickets.class4kids.co.uk/). Both ClassForKids & Little Wickets are considered joint controllers and processors under current Data Protection Legislation. Personal data is shared in order to help the Little Wickets deliver activities effectively and efficiently through the Platform, to the benefit of the Parents and Little Wickets.

You can view ClassforKids full policy terms as data controllers & personal data sharing provisions below

Please note that these policies may be regularly reviewed and updated.

12.  Other Third-Party Website Links

Little Wickets’ website and mobile app may include links to non-contracted third-party websites, plug-ins and applications. Examples of this include Twitter & Facebook.  However, clicking on those links or enabling those connections may allow third parties to collect or share data about you. As users of these services Little Wickets does check their compliance to current Data Legislation, for its own purposes, 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 notice of every website you visit.

13. International

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers (eg. Mail Chimp) are based outside the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
• Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at info@littlewickets.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

14. Payments & Financial records

All online card Payments are processed through ClassForKids via Stripe. Class4Kids charges a direct platform fee, which only applies if the payment is made through the Class4Kids platform. The fee covers the recording of transactions and movement of funds. The level of platform fees charged is at the discretion of ClassForKids. Little Wickets passes this cost onto customers and does not benefit from them. All financial and personal data relating to online payments through the Class4Kids platform are controlled and processed by ClassForKids & Stripe.

However, you can choose to register your interest in Little Wickets’ activities online through ClassForKids and pay Little Wickets Direct by BACS or cheque at no additional cost. The amount & details of direct payments received by Little Wickets are recorded on the ClassForKids cloud-based platform. Where direct payments are made to Little Wickets’ bank account,  individual financial data bank is not recorded or held Little Wickets or ClassForKids, your financial data is managed direct between Little Wickets’ bank (Nat West) and the customer.

Your bank account details may be requested, processed & held by Little Wickets to facilitate refunds.  These personal financial records are subject to the same rigorous data protection processes as all other personal data.

15. Data Security

Little Wickets is committed to ensuring that identifiable information is secure to comply with current Data Protection legislation. In order to prevent unauthorised access or disclosure, we have put in place appropriate security, physical, electronic and managerial procedures, barriers & measures to safeguard and secure the information we collect and store digitally (including cloud-based systems) and on paper. These safeguards include but are not limited to SSL encrypted website, individual account password protection and shredding documents.

We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. 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 inform you and any applicable regulator of a breach where we are legally required to do so. As an example, under current GDPR Legislation we would notify the ICO if a data breach could result in discrimination, damage to reputation, financial loss, loss of confidentiality or any other significant economic or social disadvantage to individuals and follow the ICO’s guidance in informing the individuals concerned.

16 Data Retention

Little Wickets  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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years from the end of the last company financial year they relate to, or longer if a customer’s transaction covers more than one of the company’s accounting periods for tax purposes.

In some circumstances you can ask us to delete your data: see paragraph 17 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.

17. Your Legal Rights

You have the following rights under Data Protection Legislation;

  • The right to be informed
  • The right of access
  • The right to rectification/correction
  • The right to erasure (also known as the ‘right to be forgotten’)
  • The right to restrict processing
  • The right to data portability
  • The right to object and withdraw consent
  • Rights with respect to automated decision-making and profiling

You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above or are not happy with any aspect of how we collect and/or use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you, please contact Little Wickets’ Data Controller Chloe Williams in writing at the address listed in paragraph 1 or email her at chloe@littlewickets.com

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.

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, if Little Wickets has already complied with all legal requirements. If we refuse a request, we will inform you why without undue delay and within one month of the request. You will have the right to complain to the supervisory authority and to a judicial remedy

We aim 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.