1. Introduction

1.1 We recognise the importance of protecting the privacy of Personal Data or personally identifiable information, being information which relates to an identifiable individual (“Personal Data”). We respect the rights of such individuals whose Personal Data we process (and in some cases as employer ourselves control) and the obligations imposed by applicable law and are committed to protecting your privacy in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679 (“GDPR”) but for the purposes of this Privacy Policy further includes The Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2019 (“UK privacy laws”), the ePrivacy Directive and other applicable law, (the “Data Protection Acts”) and Statutory Instrument 336 of 2011 - European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011. The following Privacy Policy discloses what Personal Data we gather, how we use it, and how to correct or change it.

1.2 This Privacy Policy applies to:

1.2.1 your use of our website;

1.2.2 all third-party services with which we share personal data as this Privacy Policy provides;

1.2.3 any use by you of our products or services;

1.2.4 any Personal Data that you supply to us or make available through any medium.

1.3 We do not share your Personal Data with any external third parties unless there is a lawful basis to share it pursuant to Data Protection Acts. We are very mindful of the sensitivity of your Personal Data and have taken all appropriate technical and organisational measures to ensure that your Personal Data is accurate and up-to-date, not excessive, properly protected and held in the strictest confidence.

1.4 If you wish your details to be removed from our database, or to update any of your details (or for any other reason outlined in Section 6 below) please contact us using the details as set out in Section 3 below.

1.5 GPS understands that your privacy is important to you and that you care about how your Personal Data is used and shared online. We respect and value the privacy of everyone who visits this website or uses our products or services, and who provides us with their Personal Data in whatever form and through whatever other medium. We will only collect and use Personal Data in ways that are described here, and in a manner that is consistent with our obligations and your rights under the law.

1.6 We do not collect any information from anyone under 16 years of age. Our Site, products and services are all directed to people who are at least 16 years old or older.

2. Definitions and Interpretation

2.1 In this Privacy Policy and in our Terms of Use, the following terms shall have the following meanings:

AI Tools means any artificial intelligence (AI) or machine learning (ML) or deep learning (DL) system whether publicly accessible or hosted privately. It includes statistical learning algorithms, models (including large language models), neural networks, and related hardware or equipment capable of generating various types of content (including text, images, video, audio, or computer code) based on user-supplied prompts. It also includes generative AI which can create new content, such as text, images, music, or videos, based on the data it has been trained on.

Cookie means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 14, below.

Cookie Law means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as updated from time to time.

Input means, in respect of AI Tools, to input, enter, post, upload, submit, transfer, transmit, disclose, expose or otherwise provide or make available or process by or through AI Tools, or collect, download or otherwise receive by AI Tools for the purposes of summarisation, translation, analysis, retention, storage, training, aggregation, combining or comingling with other data, validation, improvement as or in prompts for any generative AI Tools or any other processing or purpose.

Our Site means this website.

Output means information, data, databases, materials, text, images, or other content (including text, numbers, images, photos, graphics, video, audio or computer code) generated, produced or otherwise created by AI Tools. All Outputs of AI Tools which are included in the Services or deliverables are Client Confidential Information and IPR.

Personal Data means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site or directly through any other medium. This definition shall, where applicable, incorporate the definitions provided in UK privacy laws.

3. About Us and Contact

3.1 Our Site is owned and operated by GPS Network Limited, a limited company registered in England under company number 15718165 (“GPS”, “We”, “Us”). GPS is the Data Controller (as defined in GDPR) in respect of the Personal Data which you have shared with us pursuant to this Privacy Policy.

3.2 When you contact us through this website by way of a general enquiry or in order to find out more about one of our products or services, you consent to our retention of your email address and name for the purpose of responding to your enquiry. We shall hold this personal data as Data Controller in accordance with this Policy. Where your employer has subscribed to one of our products or services and submitted your Personal Data, your employer’s privacy policy notice and contract with you will apply. In the first instance you should address any queries to your employer. We shall also control and process such Personal Data as this policy provides in order to fulfil our contract with your employer and otherwise for lawful purposes within UK privacy laws.

Please note that the transmission of your Personal Data in response to the Contact Us form will be unencrypted.

3.3 If you have any questions about Our Site or this Privacy Policy, what Personal Data we collect about you and how it is used, please contact us by email at info@gpsnet.org. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you. We shall endeavour to respond within 30 days but may first ask you to verify who you are.

4. Third Party Services

4.1 Our Site, and communications sent out by any of the third-party services that we use for communication, marketing or other purposes such as WhatsApp may contain links to other websites, products and services. Please note that we have no control over how your Personal Data is collected, stored, or used by WhatsApp, other websites linked to our website or other services; please check the privacy policies of any such websites, products and services before providing any Personal Data to them.

5. Your Rights in respect of your Personal Data

5.1 If you wish to confirm that we are processing your Personal Data, or to have access to the Personal Data we may have about you, please contact us.

5.2 You have various rights in respect of your Personal Data which can be summarised as follows:

5.2.1 The right to be informed.

5.2.2 The right of access.

5.2.3 The right to rectification.

5.2.4 The right to erasure.

5.2.5 The right to restrict processing.

5.2.6 The right to data portability.

5.2.7 The right to object.

5.2.8 Rights in relation to automated decision making and profiling.

5.3 Please contact us in writing with any requests and provide verification that you are who you say you are. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

5.4 For further information about your rights, please contact the Information Commissioner’s Office (https://ico.org.uk/make-a-complaint/).

6. What Data Do We Collect?

6.1 When you contact us through Our Site or through other media such as WhatsApp, by way of a general enquiry or in order to find out more about us, you consent to our retention of your email address and name for the purpose of responding to your enquiry.

6.2 We collect and process the following Personal Data:

6.2.1 From Our Site: Name, Email address, Postcode, IP address, Web browser type and version, Operating System.

6.2.2 Through any other medium: Name, Contact information such as postal addresses, email addresses and telephone numbers.

6.2.3 Through one of our events: Name, Contact information such as postal addresses, email addresses and telephone numbers, Event photo (unless you object).

6.2.4 When you are using our secure online donation pages (when available), your donation is processed by a third-party payment processor.

7. How Do We Use Your Personal Data?

7.1 The provision of your Personal Data is voluntary. You can request that we delete it at any time.

7.2 All Personal Data is processed and stored securely.

7.3 When your Personal Data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.

7.4 Our use of your Personal Data will always have a lawful basis.

7.5 With your consent, and/or where permitted by law, we may also use your data for marketing purposes.

7.6 Third parties (including YouTube) whose content appears on Our Site may use third party Cookies.

7.7 The accuracy and relevance of Personal Data shall be checked periodically.

8. How And Where Do We Store Your Data?

8.1 We only keep your Personal Data for as long as we need to.

8.2 Your Personal Data will only be stored in the United Kingdom.

8.3 Data security is very important to us, and we have taken suitable measures to safeguard and secure data collected through Our Site and from any other sources.

9. How We Share Your Data

9.1 We will not share any of your Personal Data with any third parties for any purposes unless you have given us your permission to do so.

9.2 We may be legally required to share certain data held by us.

9.3 Where you have shared your personal data with us through the medium of a third party platform such as WhatsApp, you are directed to their privacy policy and terms of use.

10. What Happens If Our Business Changes Hands?

10.1 We may, from time to time, expand or reduce our business.

10.2 In the event that any of your Personal Data is to be transferred, you will be contacted in advance and informed of the changes.

11. How Can You Control Your Data?

11.1 In addition to your rights under UK privacy laws, you may be given options to restrict our use of your Personal Data.

11.2 You may also wish to sign up to one or more preference services operating in the UK (TPS, CTPS, MPS).

12. Your Right To Withhold Information

12.1 You may access certain areas of Our Site without providing any Personal Data.

13. How Can You Access Your Data?

13.1 You have the right to ask for a copy of any of your Personal Data held by us.

13.2 We reserve the right to charge fees for manifestly unfounded or excessive requests.

14. Our Use Of Cookies

14.1 Our Site may place and access certain first party Cookies.

14.2 By using Our Site you may also receive certain third party Cookies.

14.3 All Cookies used by and on Our Site are used in accordance with current Cookie Law.

14.5 Certain features of Our Site depend on Cookies to function.

14.6 The following first party Cookies may be placed on your computer or device: ‘gdpr cookie accept’.

14.7 Our Site does not currently use analytics services.

14.8 You can enable or disable Cookies in your browser.

14.9 You can choose to delete Cookies at any time.

14.10 It is recommended that you keep your internet browser and operating system up to date.

15. Changes To Our Privacy Policy

15.1 We recommend that you check this page regularly to keep up to date.

16. You are referred to Our Site Terms of Use which apply to all uses of the website, our products and services.