Sleep Pod is committed to protecting the privacy and security of your personal information. This privacy notice describes how we collect and use personal information about you in accordance with data protection law. Please read it carefully. 

Data protection law says that the personal information we hold about you must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely

If you have any questions about this notice or how we collect and use personal information about you please contact us.

1. INFORMATION ABOUT US

We are Sleep Pod, a charity registered in England with charity number 1187295. Our registered office is at Number 22, Mount Ephraim, Tunbridge Wells, Kent TN48AS. If you have any questions about our charity or our use of data, please contact us.

2. INFORMATION WE COLLECT

Correspondence and participation. Where you correspond with us (for example by email, telephone, post, SMS or via our website), support us financially or you participate in one of our charitable activities we may collect information about you such as your name, contact details, company details and details about your interaction with us.

Photos and promotional information. Where you take part in our charitable activities, we may take photographs or other recordings or ask you to provide testimonials or other information for use to promote our charity. We may display and publish this content on our platforms as necessary for our legitimate interests in promoting our charity. This information is kept and published or displayed by us for as long as we consider it relevant for those purposes. If we are displaying or publishing information based on your consent, you have the right to withdraw that consent at any time.

Professional information. If you work for one of our supporters, suppliers or business partners, the information we collect about you may include your contact information, details of your employment and our relationship with your organisation. This information may be collected directly from you, or provided by your organisation. 

Emergency contacts. If you are listed as an emergency contact by a participants in one of our charitable activities, we will hold your name, contact details and details of your relationship with that participant. We will use this to contact you if required in an emergency.

Social media. If we engage with you on social media, we may use information you share with us (including your social media handle or profile) or which is available from your account to inform our correspondence with you.

Website. We may collect information about you and your use of our website via technical means such as cookies, webpage counters and other analytics tools. This may include your IP address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access a website. We use this as necessary for our legitimate interests in administering and improving our website and its content.

3. HOW WE USE YOUR INFORMATION

We will keep and use the information we collect for the purposes of carrying out our charitable activities, performing our obligations to you and other third parties, complying with any legal requirements and for our legitimate interests, as well as to review and improve our operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.

We may also use your name and contact details (such as your email address, phone number or address) in order to send you updates and information about our future charitable activities which we think you might be interested in.

You always have the right to “opt out” of receiving our updates. You can exercise the right at any time by contacting us. If we send you any update emails, we will provide an unsubscribe option to allow you to opt out of any further update emails. 

Where we consider there to be a risk that we may need to defend or bring legal claims, we may retain your personal information as necessary for our legitimate interests in ensuring that we can properly bring or defend legal claims. We may also need to share this information with our insurers or legal advisers. 

4. WHY ELSE DO WE KEEP YOUR INFORMATION

Common uses of your information. We will only use your personal information when the law allows us to do so. Although in limited circumstances we may use your information because you have specifically consented to it, we generally use your information in the ways set out in this notice because:

• we need to comply with a legal obligation.
• it is necessary for our legitimate interests (or those of a third party) and your interests and rights do not override those interests.
• we need to protect your interests (or someone else’s interests) or where it is needed in the public interest (although these circumstances are likely to be rare).

Change of purpose. We will only use your personal information for the purposes for which we collected it as set out in this notice, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

5. SHARING YOUR INFORMATION

 We never sell your data to third parties. But we may need to share your information with third parties, including third-party service providers and other entities in our group. Third parties are required to respect the security of your personal information and to treat it in accordance with the law. 

Why might we share your personal information with third parties? We may share your personal information with third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of us, our customers, or others or where we have another legitimate interest in doing so. This may include exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

What about other third parties? We may share your personal information with other third parties, for example in the event of a potential merger of our charity with another charity. We may also need to share your personal information with a regulator or to otherwise comply with the law.

6. WHERE DO WE STORE YOUR INFORMATION

Our office headquarters and main data centre is located in the UK. However, the information that we hold about you may be transferred to, and stored at, a destination outside the UK and the EU and it may also be processed by staff operating outside the UK and EU who work for us or for one of our service providers. 

We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy notice.

Some countries or organisations outside of the UK and the EU which we may transfer your information to will have an “adequacy decision” in place, meaning the EU considers them to have an adequate data protection regime in place. These are set out on the European Commission website: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

If we transfer data to countries or organisations outside of the UK and the EU which the EU does not consider to have an adequate data protection regime in place, we will ensure that appropriate safeguards (for example, model clauses approved by the EU or a data protection authority) are put in place where required.  To obtain more details of these safeguards, please contact us.

7. DATA SECURITY

As well as the measures set out above in relation to sharing of your information, we have put in place appropriate internal security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where necessary.

8. HOW LONG WILL WE KEEP YOUR INFORMATION FOR?

We only keep information for as long as is 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 information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

9. YOUR RIGHTS

Data protection law gives you a number of rights when it comes to personal information we hold about you.  The key rights are set out below. More information about your rights can be obtained from the Information Commissioner’s Office (ICO). Under certain circumstances, by law you have the right to:

• Be informed in a clear, transparent and easily understandable way about how we use your personal information and about your rights. This is why we are providing you with the information in this notice. If you require any further information about how we use your personal information, please let us know.
• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it (for instance, we may need to continue using your personal data to comply with our legal obligations). You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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 us using your information on this basis and we do not have a compelling legitimate basis for doing so which overrides your rights, interests and freedoms (for instance, we may need it to defend a legal claim). You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party where you provided it to us and we are using it based on your consent, or to carry out a contract with you, and we process it using automated means.
• Withdraw consent. In the limited circumstances where we are relying on your consent (as opposed to the other bases set out above) to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another compelling legitimate interest in doing so.
• Lodge a complaint. If you think that we are using your information in a way which breaches data protection law, you have the right to lodge a complaint with your national data protection supervisory authority (if you are in the UK, this will be the ICO).

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, withdraw your consent to the processing of your personal information or request that we transfer a copy of your personal information to another party, please contact us.

No fee usually required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you. We may need to request specific information from you to help us understand the nature of your request, to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. If we request any identification from you for this purpose, it is on the basis that it is necessary to comply with our legal obligations, and we will only keep and use this until your identity has been verified.

Timescale. Please consider your request responsibly before submitting it. We will respond to your request as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will let you know.

10. CHANGES TO THIS PRIVACY NOTICE

Any changes we make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or otherwise. Please check back frequently to see any updates or changes to our privacy notice.