INTRODUCTION

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SENSE Consortium is a trading style of Sense Holding Group LTD, a private company limited by shares, registered in England and Wales under company number 10429034  (Registered VAT number 432289984.) and whose registered address is 2 Adelaide Street, St. Albans, England, AL3 5BH (Sense Consortium, we, us or our).

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This policy explains how SENSE Consortium uses the personal data we collect from you when you use our website at https://senseconsortium.com/ (our Website) to find out more about our services or whitepapers, to request us to make contact with you about an enquiry you have or a request for services or events or  to sign up for a newsletter. Please note that our Website may contain links to third party websites / digital platforms which are provided for your convenience. We are only responsible for the privacy practices and security of our Website. We recommend that you check the privacy and security policies and procedures of each and every other website / digital platform that you visit.

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This policy applies where we are acting as a data controller with respect to personal data we collect, where we determine the purposes for which we collect and store personal data and means of the processing of personal data.

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The type of the personal data we store about you is under your control, and you can specify your preferences for receiving direct marketing communications, and limit the collection, sharing, and internal publication[1] of your personal data. You can specify your privacy preferences by emailing info@senseconsortium.com

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CONTENTS

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Important information and who we are

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1. What data do we collect?

2. How do we collect your data?

3. How will we use your data?

4. How do we store your data?

5. Marketing

6. Your rights

7. How do we use cookies? /What kind of cookies do we use? / How to manage your cookies

8. Evidencing our data protection process

9. Changes to our privacy policy

10. Contact us

11. How to contact the appropriate authorities

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IMPORTANT INFORMATION AND WHO WE ARE:

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Sense Holdings Group LTD, trading as SENSE Consortium, is the data controller and responsible for your personal data.

We have appointed a data privacy manager (DPM).  If you have any questions about this Privacy Notice or our data protection practices please contact the DPM.

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CONTACT DETAILS

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Name of DPM:  

Helene Stanway

Email address:  

helene.stanway@senseconsortium.com

Postal address:  

2 Adelaide Street, St. Albans, England, AL3 5BH

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You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO); see Section 11 below.

We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

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1. WHAT DATA DO WE COLLECT?

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Sense Consortium collects the following data:

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• Personal identification information including:first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender (first name, surname, email address, company name, job title)

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• Contact Data including:

        billing address, delivery address, email address and telephone numbers

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• Transaction Data including details about payments to and from you, and other details of products, digital content and/or services you have purchased from us

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• Details of any previous services you have used, provided by SENSE Consortium.

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• Any communication preferences you have specified regarding marketing you receive, as well as services you may be interested in

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We may also store information from cookies placed on our Website, such as your IP address and location; the vast majority of this data is recorded anonymously; that is, this information cannot be associated with you individually. On some occasions, like when we need to record your preferences, this information may be related to you, for example through your IP address. This information is stored in a way that ensures it cannot be attributed to you, and can’t be linked to additional information we store about you separately and securely on Sense Consortium’s systems. This is called pseudonymous data, as it identifies your user in order to recognise your preferences, however, it does not relate to any personal information beyond the unique reference number it applies to you as you enter our site.

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2. HOW DO WE COLLECT YOUR DATA?

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You directly provide SENSE Consortium with of the data we collect.

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We collect and process data when you:

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• Register interest in any of our digital content, downloads and services or marketing materials through our Website, i.e. submitting your contact details to access our whitepapers, and/or subscribe to our emails

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• Register for one of our SENSE Consortium Live events, where we will store any information you provided as well as whether or not you attended the event

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• Register your information entirely voluntarily in any other method, i.e. registering interest in our services at a conference, where you may sign a physical form

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• Use or view our website via your browser’s cookies

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SENSE Consortium may also receive additional data that is available in the public domain, subject to your voluntary submission of your own details via one of the methods above.

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We also collect, use and share aggregated data such as statistical or demographic data for any purpose relevant to our Website and services.  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 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.

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Where we need to collect personal data to follow up an enquiry from our Website, by law, or under the terms of a contract we have with you, and you fail to provide that personal data when requested, we may not be able to follow up on your enquiry or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

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3. HOW WILL WE USE YOUR DATA?

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Under the Data Protection Legislation (that is the Data Protection Act 2018, the General Data Protection Regulations (Regulation (EU) 2016/679, and all applicable laws and regulations relating to processing of personal data and privacy, in each case as amended or substituted from time to time), we must always have a lawful basis for using personal data.  Most commonly, we will use your personal data in the following circumstances:

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1. Where we need to use your personal data for performance of the Contract we are about to enter into or have entered into with you.

2. Where it is necessary because we or a third party has a Legitimate Interest in doing so and your interests and fundamental rights do not override those interests.

3. Where we need to Comply with a Legal Obligation.

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For these purposes, the following phrases have the following meanings:

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• Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or take steps at your request before entering into such a contract.

• Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/content and the best and most secure experience. We make sure 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 to 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.

• Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

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Generally, we do not rely on consent as a legal basis for processing your personal data except where you sign up to our newsletter or register for events, 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.

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SENSE Consortium collects your data so that we can:

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• Register you as a new member of SENSE Consortium

• Supply our services to you

• Manage our relationship with you including notifying you about changes to our terms or privacy policy and asking you to leave a review or take a survey

• Administer and protect SENSE Consortium, services and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

• Manage payment for our services including managing payments, fees, charges and for collecting and recovering money owed to us

• Use data analytics to improve our Website, services, marketing, membership relationship and experiences

• Supplying you with information by email and post that you have opted-in to (you may opt-out at any time by contacting us at crew@thecamelotnetwork.com

• Inform you of any security breaches that may have affected your data

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When signing up to receive our newsletter, we use this data to:

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• Send you our newsletter, no more than weekly

• Notify you about upcoming SENSE Consortium events

• We collect this data using the lawful basis: Legitimate Interest and Consent and complying with our legal obligations.

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When you submit your details in order to download content from our website, we use this data to:

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• Send you further information regarding the services you registered your interest in

• Process your future requests for discussion or performance of a contract

• We collect this data using the lawful basis: Performance of Contract, Legitimate Interest and complying with our legal obligations.

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When registering for any SENSE Consortium Live event, we will use this data to:

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• Process your registration through our online event host site (specified in section 4), where the event is hosted virtually

• Send you communications regarding your registration through our chosen online event host site (specified in section 4), including your unique join link, as well as outputs from the event through our email marketing platform (specified in section 4)

• We reserve the right to send you additional information both before and after the event, relating solely to the specific event you registered for, i.e. resources discussed during the event

• Where you have attended a physical event, we may also record or photograph the event for use in our marketing materials. If you wish not to be photographed or filmed, you can notify us at any time. Where this is taking place, we will inform you how to request not to be filmed or photographed, where it is disproportionate to obtain signed consent from all attendees.

• We collect this data using the lawful basis: Performance of Contract, Legitimate Interest and complying with legal obligation.

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We may also send you invitations to future events we host, within the industry you have previously registered your interest in

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• We collect this data using the lawful basis: Legitimate Interest

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4. HOW DO WE STORE YOUR DATA?

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SENSE Consortium acts as data controller, securely storing your data through our online email marketing platform (see below for further details of the persons with whom we share your personal data), with whom we have a contractual relationship in order to assist in carrying out our services and marketing, specifying they may never sell or share your information.

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SENSE Consortium will keep your personal data for no longer than necessary; this timescale is dependent on the nature of your relationship with us.

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Subscribers will continue to receive updates via our email marketing platform until:

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• You unsubscribe, therefore revoking consent to continue to send you marketing communications

• You are an active subscriber and fail to re-consent within 6 months of being informed of the requirement to re-consent, after our standard re-consent period of 4 years

• You fail to re-verify your subscription when prompted after being an inactive subscriber for 6 months, meaning you aren’t opening any of our emails

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Once you are removed from our mailing list, we will not send you any marketing communications; however, where you have shown interest in a particular service, we reserve the right to continue to send you related information about our services under the lawful basis of legitimate interest. You may revoke this authorisation at any time by contacting info@senseconsortium.com, or otherwise invoking one of your rights, stated in section 6 of this document.

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We share personal data with the following third parties, who may act as data processors as set out below:

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• Demio, Inc.

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Data is transferred outside of the European Economic Area to the United States in order to utilise Demio, Inc.’s services. Following the CJEU invalidation of the Privacy Shield on 16th July 2020, Demio assured its customers that they’ve updated their Data Processing Agreement and have the EU Commission’s Standard Contractual Clauses (SCC’s) in place to continue safely transferring and processing your personal data.

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They also maintain a record of processing activities, as per the GDPR Article 30 [access here: https://gdpr-info.eu/art-30-gdpr/].

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This replaces the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework in order to maintain protection regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.

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• ConvertKit

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Data is transferred outside of the European Economic Area to the United States in order to utilise ConvertKit’s services. Following the CJEU invalidation of the Privacy Shield on 16th July 2020, ConvertKit assured its customers that they’ve updated their Data Processing Agreement and have Standard Contractual Clauses (SCC’s) in place to continue safely transferring and processing your personal data.

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This replaces the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework in order to maintain protection regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.

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• Hubspot

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Data is transferred outside of the European Economic Area to the United States in order to utilise Hubspot’s services. Following the CJEU invalidation of the Privacy Shield on 16th July 2020, Hubspot assured its customers that their Data Processing Agreement already covers SSCs, therefore data transferred from the EU has been continually protected under validated security and data privacy laws.

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This replaces the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework in order to maintain protection regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.

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• Pipedrive

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Data is transferred outside of the European Economic Area to the United States in order to utilise Pipedrive’s services. Following the CJEU invalidation of the Privacy Shield on 16th July 2020, Pipedrive assured its customers that their Data Processing Agreement already covers SSCs, therefore data transferred from the EU has been continually protected under validated security and data privacy laws.

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This replaces the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework in order to maintain protection regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.

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• AddEvent, Inc.

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Data is transferred outside of the European Economic Area to the United States in order to utilise AddEvent Inc.’s services. Their privacy policy, accessible here, reassures consumers that “we take legally required steps to make sure that appropriate safeguards are in place to protect your Personal Data” during transfers of data to or from the country of origin. AddEvent Inc. merely provides the tools for us to implement calendar and invite management, where we remain the Data Controller. AddEvent Inc. does not opt for the standard European Standard Contractual Clauses (SSCs), however, they have written their own contractual clauses, which are available here, endorsed by their DPA as required by European Commission.

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These replace the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework in order to maintain protection regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.

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• Stripe, Inc.

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Data is transferred outside of the European Economic Area to the United States in order to utilise AddEvent Inc.’s services. Following the CJEU invalidation of the Privacy Shield on 16th July 2020, Strip, Inc. assured its customers that their Data Processing Agreement already covers SSCs, therefore data transferred from the EU has been continually protected under validated security and data privacy laws.

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Stripe also applies technical and organisational measures to strengthen their security measures, of which details are accessible through the Stripe Privacy Centre.

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This replaces the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework in order to maintain protection regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.

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• Google Analytics

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Data is not transferred outside of the European Economic Area.

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We reserve the right to interact with additional third-parties, who may have access to, or process, personal data in order to provide services for us. We will limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them will require maintained confidentiality of such information. Any such situation occurs, this privacy policy will be updated and made accessible, however, we will only inform data subjects in case of significant changes to this policy.

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There are certain situations in which we may share access to your personal data without your explicit consent; for example, if we are required to do so by the law, to protect the life of an individual, or to comply with any valid legal process, government request, rule or regulation.

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5. MARKETING

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SENSE Consortium will send you marketing materials only if you have consented to receive marketing communications from us, or in the case of a recorded previous Legitimate Interest, as specified in section 3 of this document.

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You have the right to stop receiving marketing communications or otherwise alter your marketing preferences at any time, using the link at the bottom of all marketing emails, or by contacting crew@thecamelotnetwork.com.

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6. YOUR RIGHTS

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SENSE Consortium would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:

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• The right to access

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You have the right to request SENSE Consortium for copies of your personal data, commonly known as “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.

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• The right to rectification

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You have the right to request SENSE Consortium corrects any information you believe is inaccurate. You also have the right to request SENSE Consortium to complete information that you believe is incomplete, though we may need to verify the accuracy of the new data you provide to us.

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• The right to erasure

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You have the right to request that SENSE Consortium erase your personal data (sometimes known as the right to be forgotten). 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.

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•  The right to restrict processing

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You have the right to request that SENSE Consortium restrict the processing of your personal data, under certain conditions. 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.

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• The right to object to processing

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You have the right to object to SENSE Consortium’s 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..

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• The right to data portability

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You have the right to request that SENSE Consortium transfer what we have collected to another organisation, or directly to you, under certain conditions. 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.

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• The right to withdraw consent

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You have the right to withdraw consent 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.

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If you wish to exercise any of the rights set out above, please email us at crew@thecamelotnetwork.com.

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• 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.

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• 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.

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If you make a request, we have one month to respond to your request.  Occasionally it could 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.

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