Privacy Policy_
UK VETERANS LIMITED
Privacy Notice
Last updated: 28th June 2024
1. Introduction
This Privacy Notice provides details about how UK Veterans Limited ('we', 'us' and 'our'), which operates the weServed platform for military veterans, processes your personal data as a controller, including how and why we use your personal data and how we keep it safe. It also explains the rights you have over your personal data.
This Privacy Notice is intended for our Website visitors, App users, customers or prospective customers, members or membership applicants, attendees at our events and subscribers to, or readers of, our publications or newsletters ('you' and 'your').
You should read this Privacy Notice so that you know what we do with your personal data. Please also read any other privacy notices that we may provide to you from time to time that may apply to our use of your personal data in specific circumstances.
Please see the 'Contact' section 15 below for details of how to contact us.
2. Explanation of terms
In this Privacy Notice:
'personal data' (also referred to in this Privacy Notice as'personal details') means any information that relates to you from which you can be directly or indirectly identified.
'process' means any activity relating to personal data, including collection, use, sharing, storage and transmission.
'controller' is a legal term and refers to the company that makes decisions about how and why your personal data is processed and is therefore responsible for ensuring that the processing is done in accordance with relevant data protection laws.
'Partners' means third parties with whom we have contracted in order to provide you with offers, good and/or services.
'Website' means our website, https://we-served.com/ and any pages linked to on our website, excluding those websites or pages run by third parties.
'App' means our mobile application, weServed, which you have downloaded to your mobile device.
3. How do we obtain your information?
Most of the personal data we process is provided to us directly by you when you engage with us, such as when you:
- Enter your personal details into our App or Website to register with us or in response to a request from us;
- Enter your payment details into any web form we make available to you;
- Interact with our App or Website, such as when scrolling and following links;
- Contact us via the App or Website for any reason including submitting a query or request; or
- Generate or upload any content on the App or Website, such as leaving a comment, sending messages, engaging with other users of the Website or App, uploading a profile picture or setting any preferences.
We may also collect personal data from third party sources, such as our Partners or publicly available databases.
If you submit any personal data relating to another person, you represent that you are authorised by that person to do so and to permit us to use the information in accordance with this Privacy Notice.
4. How do we use cookies and similar technologies?
We may also use cookies and similar technologies to collect further information about you on the Website or App. Please click here for further information about how we use cookies[and similar technologies].
5. What information do we collect?
We collect the following personal data about you:
- Name, email address, home address and telephone number
- Regimental information including regiment, rank service number and exit date
- Any information necessary to verify your status as an armed forces veteran
- Information on the way you use our App or Website, including click-through interactions, viewing video or photo content, and liking posts
- Technical and usage information (such as your IP address, time zone setting and location)
- Online account information, including usernames and passwords which you generate in the sign-up process and use to log in
- Payment information, including your billing name and address, method of payment, bank account details and payment card information
- Information provided to us from our Partners
- Any messages, questions, comments or enquiries you send to, or share with, us which may contain personal details about you
- Any interactions with other users on the Website or App which may contain personal details such as your personal opinions
- Any content you generate or upload to the Website or App, including where you upload your profile picture or videos
- Feedback and surveys
- Your direct marketing and communication preferences
- Any other information you provide to us voluntarily
Any credit/debit card payments and other payments you make through our Website or App will be processed by our third-party payment provider. Payment data you submit will be securely stored and encrypted by our payment provider using up-to-date industry standards.
6. What are our lawful bases for processing your personal data?
We ensure that we have a lawful basis or bases for processing your personal data. Our lawful bases for processing your personal data are as follows:
- Necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract with us
- Our legitimate interests (please see the table below for descriptions of our legitimate interests)
- Your consent
- Necessary for the compliance with a legal obligation to which we are subject
We do not ourselves request any sensitive information (such as health/disability information, sexual orientation or racial or ethnic origin) or criminal conviction/offence data from you. Please refrain from providing this sensitive or criminal data through the App and/or Website. Note that our Partners may collect this information separately and this information is not seen by us. You should read our Partners' privacy notices for information about how they process your personal data.
7. How and why do we use your information?
Please see the table below for details of the different purposes for which we use your personal data, as well as the lawful basis or bases relied upon for each purpose of use. Where relevant, we also describe our legitimate interests in the Description column:
Purpose | Description | Lawful basis or bases |
Registration and providing our services | To manage our relationship with you and to provide you with the services which we have agreed to provide, including setting up your membership, providing links to our affiliates' services and any messaging platform we may facilitate. | Necessary for the performance of a contract with you Legitimate interests |
Managing your requests and enquiries | To deal with and respond to your enquiries and communications, we may process information contained in or relating to any communication that you send to us, including any surveys you complete and feedback you provide. This data may include the communication content and metadata associated with the communication. | Necessary for the performance of a contract with you Legitimate interests |
Analytics and business management | To manage our business, operate our Website and App, provide and evaluate our services and partnerships with third party providers such as our Partners. | Legitimate interests |
Marketing and promotions | To provide you with news, offers and promotions from us which may be of interest to you. | Consent Legitimate interests |
Internal Business Purposes | For our internal business purposes, such as data analysis, audits, market research, developing new products, improving our services, obtaining statistical information, identifying usage trends and visiting patterns, determining the effectiveness of our promotions and meeting contractual obligations. Managing our business also includes managing potential sales or acquisitions of the whole or part of our business. | Legitimate interests |
Technical Analysis | For troubleshooting, testing and checking for illegal activity, as part of our efforts to keep our Website, App, network and information systems secure and robust. | Legitimate interests |
Administrative and Other Communications | To send you important information regarding our Sites, changes to our terms, conditions, and policies, or other administrative information (e.g., information about your membership), to enforce our terms and conditions and policies, to provide you with customer/user support, to contact you for public health reasons and to comply with government or regulator guidelines, regulations and mandates. | Legitimate interests Legal obligation |
To defend and initiate legal claims | To protect our interests by either defending or commencing a legal claim. | Legitimate interests Legal obligation |
8. Do we share the information we receive?
We may share your personal data with third party service providers outside our group to provide us with services, such as (i) card processing or payment service providers; (ii) IT suppliers and contractors (e.g. data hosting providers); (iii) analytics providers/ web analytics providers; (iv) providers of digital advertising services; and (v) providers of CRM, marketing and sales software solutions.
We carry out due diligence to check that these service providers have appropriate security in place to protect your personal data and we enter into written contracts with them to impose appropriate security obligations on them.
We may also share your personal data with third parties who act as controllers of that data. We may share your personal data with:
- consultants and professional advisors, including our lawyers and accountants;
- prospective sellers, buyers or other third parties if we transfer, purchase, reorganise, merge or sell any part of our business;
- courts and court-appointed persons/entities;
- trade associations;
- identity verification service providers;
- our insurers; and
- government departments and statutory and regulatory bodies, including data protection regulators, law enforcement and tax/revenue offices.
We may provide personal data about you to our Partners to enable them to provide services which you may request or be interested in. They are responsible for the way in which they process and handle your personal data and do so independently of us. Please read the privacy notices provided by these Partners for further information.
9. Is your personal data sent outside the United Kingdom?
We may share your personal data with our service providers, and other third parties that may be located in other countries, Although the data protection laws of these countries may differ from those in the United Kingdom, we will take appropriate measures to ensure that your personal data is handled as described in this Privacy Notice and in accordance with applicable law.
If we transfer your personal data outside the UK, we either rely on UK adequacy regulations recognising the relevant country or jurisdiction as a safe jurisdiction to which UK personal data may be transferred or we will implement appropriate safeguards as required by data protection law to protect your personal data, such as standard contractual clauses. You may obtain a copy of these clauses by contacting us in accordance with section 15.
10. How do we protect your personal data?
We take the security of the personal data we collect seriously. We have implemented and maintain technical and organisational security measures (as required by applicable data protection laws) to protect your personal data from accidental or unlawful destruction, damage, loss, alteration or unauthorised disclosure or access.
11. For how long will we keep your information?
We will keep your personal data for a limited period and for no longer than necessary for the purposes for which they were collected. We will generally not retain your information for more than 6 years after the date we collected it or last used it for its intended purposes, but this may vary depending on the underlying purpose and any other relevant factors, such as applicable laws and regulations.
12. What are your personal data protection rights?
Certain applicable data protection laws give you specific rights in relation to your personal data. In particular, if the processing of your personal data is subject to data protection law in the UK and EEA, you have the following rights in relation to your personal data:
Right of access: If you ask us, we will confirm whether we are processing your personal data and, subject to certain conditions, we will provide you with a copy of that personal data along with certain other details such as the purpose(s) of the data processing.
Right to rectification: If your personal data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. Please help us to keep your personal data up to date by letting us know of any changes to your personal data (including changes to your contact details) as soon as possible.
Right to erasure: Subject to certain conditions, you may ask us to delete or remove your personal data, such as where we no longer need the personal data for the purposes for which it was collected or our legal basis for the processing is your consent and you withdraw consent.
Right to restrict processing: You may ask us to restrict or 'block' the processing of your personal data in certain circumstances, such as where you contest the accuracy of the personal data or object to us processing it. We will tell you before we lift any restriction on processing.
Right to data portability: You have the right to obtain from us (or to have transferred to another controller) your personal data that we process by automated means on the basis of your consent or necessity for a contract with you. We will provide the personal data in a structured, commonly used and machine-readable format.
Right to object: You may object to our processing your personal data, and we will stop processing your personal data if (i) we are relying on a legitimate interest to process your personal data, unless we demonstrate compelling legitimate grounds for the processing or (ii) we are processing your personal data for direct marketing purposes.
Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your personal data carried out before we received notice that you wished to withdraw your consent.
13. Right of complaint to your data protection authority
If you have a concern about our privacy practices, including the way we handled your personal data, we would appreciate the opportunity to put it right. If you are not satisfied with the way we handle your personal data, you have the right to complain to the UK data protection authority, the Information Commissioner's Office (https://ico.org.uk/).
If you are located in the EEA, you have the right to complain to the competent data protection authority for your jurisdiction, a list of which can be found at https://edpb.europa.eu/about-edpb/board/members_en.
14. Changes to this Privacy Notice
We may amend and update this privacy notice from time to time. Any changes we may make to our Privacy Notice in the future will be posted to this Site. Please check back frequently to see any updates or changes to this Privacy Notice.
15. How to contact us
If you have any questions about this notice or how we handle your personal data, please contact us at [email protected] or write to us at: 28 The Old Town, Clapham, London SW4 0LB.
Our Data Protection Officer is Satswana Ltd. They may be contacted here: [email protected]