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PRIVACY POLICY

Privacy Policywapg2021-11-04T13:36:47+00:00

We Are Pioneer Group (WAPG) has responsibility under data protection law to
provide individuals with information about how we process their personal data.
In this policy we will provide you with information that is common to all our
processing activities, as well as explaining what rights you have to control how
we use your information and how to inform us about your wishes.

OUR COMMITMENT TO YOUR PRIVACY

In many instances when WAPG collects personal data, we are the Data Controller.
As Data Controller, we are responsible for ensuring our systems, processes,
suppliers and people comply with data protection laws in relation to the
information we handle.

All our people must abide by this policy when handling personal data and take
part in any required data protection training.

When we need to let you know about additional privacy information not contained
in this policy, such as when we are processing data on behalf of a Data
Controller, we will let you know at the point that we collect the relevant
personal data from you or within a reasonable period of obtaining your personal
data.

LAWFUL BASIS FOR PROCESSING YOUR PERSONAL DATA

Under the UK General Data Protection Regulation (UK GDPR), tailored by the Data
Protection Act 2018, we are only allowed to use your personal data if we have a
proper reason to do so.

Data protection law sets out a number of different reasons we may collect and
process your personal data. The lawful basis will depend on the specific
activity for which we are collecting your personal data, but will usually be one
of the following:

 * You have given us permission to do so: In specific situations, we can collect
   and process your data with your consent – e.g. when you sign up to receive
   email or postal communication from us. When collecting your personal data,
   we’ll always make clear to you which data is necessary in connection with
   particular activities.

 * We need to perform a contract: In some instances, we need to process your
   personal data to comply with our contractual obligations. For example, if you
   ask to attend an event and let us know about special dietary requirements, we
   need your contact details to update you about the event arrangements and to
   let you know of any changes, and we may also need to pass some of your
   personal data on to our caterer.

 * We need to comply with a legal obligation: We may be legally bound to collect
   and process your data. For example, if someone is involved in any criminal
   activity or fraud affecting us, we need to pass details, which could include
   personal data, to law enforcement.

 * It is in our legitimate interest: We require your data to pursue our
   legitimate interests in a way which might reasonably be expected as part of
   running our business and which does not materially impact your rights,
   freedom or interests. For example, we may use your event attendance history
   to offer more personalised event offers. We can only use this lawful basis if
   our legitimate interests do not override your individual interests, rights
   and freedoms.

YOUR RIGHTS

You have rights over your personal data.  Under data protection law:

 * we have to inform you about the collection and use of your personal data,
   including our purposes for processing your personal data, how long we will
   keep your data and who we will share your data with (known as the right to be
   informed);
 * you can ask whether we are processing your personal data and if so, ask for a
   copy of your information (known as the right of access);
 * you can ask for information to be corrected (known as the right to
   rectification);
 * you can ask for information to be erased or deleted (known as the right of
   erasure);
 * you can ask for us to limit or restrict processing (known as the right to
   restrict processing);
 * you can ask us to send you a copy in a structured digital format or ask for
   us to send it to another party (known as the right to data portability);
 * you can object to us processing your data, in particular where we use the
   data for direct marketing, including profiling for direct marketing
   purposes.  The right to object does not apply if we must process the data to
   meet a contractual or legal requirement (known as the right to object);
 * you have the right not to be subject to a potentially damaging decision being
   taken without human intervention (known as rights related to automated
   decision making and profiling).

Some rights, however, may be limited. We may be obliged by law or regulation to
keep information.  We must respect other people’s privacy as well, which means
we may need to redact or remove information where it includes personal data
about someone else, even if it is connected to your data.  On occasion there may
be a compelling legitimate interest to keep processing data.

If you want a copy of your data, to object to how we use your data, or ask us to
delete it or restrict how we use it or, please see ‘Getting in touch’ below.

You also have a right to complain to the data protection authority.  This can be
where you live, work or where the matter occurred. In the UK, the authority is
the Information Commissioner’s Office, please see ‘Contacting the regulator’
below

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We only keep your data for as long as is necessary for the purpose it was
collected. After that period, your data is deleted or anonymised.  We may also
aggregate your personal data with other data to use for business planning and
analysis.

WHO WILL WE SHARE YOUR DATA WITH?

At times we need to share your personal data with trusted third parties e.g.
delivery couriers, IT companies, credit card processing services and so on. We
only provide what they need and they cannot use your data for anything other
than the purposes that they have your data for. Your data is deleted or rendered
anonymous if we stop working with the third party.

In addition, we may share your personal data with competent authorities
processing personal data for legitimate law enforcement purposes.

SHARING YOUR DATA WITH THIRD PARTIES FOR THEIR OWN PURPOSES

We will never sell or trade your contact details with any third parties without
you giving us your express consent to do so e.g. if you ask to attend an event
which is being run explicitly as a joint event with a third-party.

There are some instances where we may have to share your information based on
our legal obligations, for instance:

 * Legal, compliance, regulatory and investigative purposes, including for
   government agencies and law enforcement.
 * When you exercise your rights under data protection legislation, including
   when you ask to subscribe or unsubscribe from our marketing communications.

WHERE DO WE STORE YOUR PERSONAL DATA?

Where practical, your personal data will be stored within the UK. This includes
data stored in physical format at our sites and in digital format in our own and
our service providers systems.

Sometimes we may need to send or store your data outside of the UK.  For
example, to follow your instructions, to comply with a legal duty or to work
with or receive services from our service providers who we use to support the
operation of our business. If we do transfer information outside of the UK, we
will make sure that it is protected as required under the UK GDPR, usually
through the use of one of the following safeguards:

 * Transfer it to a country with privacy laws that give the same protection as
   the UK GDPR. The UK Government has the power to determine whether a country
   has an adequate level of data protection – known as an “adequacy decision”.
 * Put in place a contract with the recipient that means they must protect it to
   the same standards as the UK or use other mechanisms and measures to achieve
   adequate protection. We also may use the Standard Contractual Clauses
   published by the UK Government for this purpose.
 * Use binding corporate rules. These are internal rules adopted by group
   companies to allow international transfers of personal data to entities
   within the same corporate group located in countries which do not provide an
   adequate level of protection.

COOKIES AND SIMILAR TECHNOLOGY

Our website, apps and marketing emails use cookies and similar technology. Full
information is in our Cookie Policy.

GETTING IN TOUCH

Our Company Secretary is responsible for overseeing and monitoring our
compliance with data protection laws and this policy.

If you want to make a request in line with your rights, you have any concerns
regarding the way in which we are processing your personal data, or you just
have a question relating to our processing of your personal data, please contact
us by email at governance@wearepioneergroup.com or write to us at:  We Are
Pioneer Group, BioCity Nottingham, Pennyfoot Street, Nottingham, NG1 1GF

CONTACTING THE REGULATOR

If you are unsatisfied with the way in which we process your personal data, we
ask that you let us know so that we can try to put things right. If we are not
able to resolve issues to your satisfaction, you can refer the matter to the
Information Commissioner’s Office by calling 0303 123 1113 or going online to
www.ico.org.uk/concerns.

LONDON HQ ADDRESS:
ST CHRISTOPHER’S HOUSE
27 ST CHRISTOPHER’S PLACE
LONDON
W1U 1NZR
UK



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