HOMELESS TO WELLNESS LIMITED

Change Ahead Non-Profit Charity and Homeless To Wellness Limited’s Privacy Policy

Definitions
• Change Ahead: Change Ahead Non-Profit Charity.
• Trustee: a trustee of Change Ahead.
• Board of Trustees: means the board of Trustees of Change Ahead from time to time.

Summary of Privacy Policy
Change Ahead (also referred to as the “Charity” or “We”) is known as the ‘Controller’ of the personal data provided to Change Ahead.

We take your right to privacy very seriously and so before you use the Change Ahead Platform, please read how we collect and use your personal data. You can also read our full Privacy Policy below.

Change Ahead and Homeless To Wellness Limited are collectively known as the ‘Controller’ of the personal data provided to us.

Why we need your personal data
• We need to collect this information about you when you sign up and each time you use the Platform so that you can get the most out of Change Ahead.
• We do not collect sensitive information such as any special category medical details and criminal records.
• We store your personal data securely.

You have consented to provide this information to us but can withdraw your consent at any time by getting in touch with Change Ahead ([email protected]).

What we do with your personal data
• We retain personal information only for as long as necessary to carry out these functions. If you notify us that you no longer wish to be listed on the database, we will delete your information as soon as possible.
• We use your data to provide information to you about items available nearby.
• We may use your information to contact you about our goods and services that we believe that you may be interested in.
• We do not share your information with anyone unless we are required to do so by law or it is necessary to make the Platform run properly.
• We do not sell your information to anyone.

All the personal data we process is located on servers within the European Economic Area (EEA) or the United States of America.

What are your rights?
• You have a right to request a copy of your personal data and you can request that your data to be deleted by making a request in writing to [email protected]. If at any point you believe the personal data we hold is incorrect you can request to have it corrected. If you wish to raise a complaint on how we have handled your personal data, you can contact us and we will investigate the matter.
• If you are not satisfied with our response or believe we are not processing your personal data in accordance with the law you can complain to the Information Commissioner’s Office (ICO).
• There are more details on your rights set out in our full Privacy Policy below.

1. Introduction
1.1 Change Ahead Non-Profit Charity and Homeless To Wellness Limited (“We”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:
• The identity of the data controller.
• What personal data is collected including the types of information we may collect or that you may provide when you download, access or use the Change Ahead Services (the “Platform”). Note: for the purposes of this policy both the website www.changeahead.org.uk and the Change Ahead platform shall be referred to as the “Platform”.
• How personal data is collected.
• Why personal data is collected.
• How we use personal data.
• How personal data is shared and with whom.
• What choices you have with respect to how personal data is used.
• How long personal data is kept.
• Your rights with respect to personal data.

1.2 This policy applies only to information we collect on the Platform, via e-mail, text and other electronic communications sent through or in connection with the Platform This policy does not apply to information that:
• we collect offline or on any other Company apps or websites (other than www.changeahead.org.uk), including websites you may access through this Platform.
• you provide to or is collected by any third party (see section 3.6 “Third-party information collection”) unless this information is provided by them to us.

1.3 Please note, we may have a separate privacy policy for our other websites and apps and third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

1.4 Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with or use this Platform. By downloading, registering with or using this Platform and, where applicable, ticking our consent boxes, you agree to this privacy policy. This policy may change from time to time (see section 11 “Changes to this privacy policy”). Unless such changes mean changes to your preferences, your continued use of this Platform after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

1.5 Users under the Age of 18: The Platform is not intended for anyone under 18 years of age, and we do not knowingly collect personal data from anyone under 18. If we learn we have collected or received personal data from anyone under 18 without verification of parental consent, we will delete that personal data. If you believe we might have any personal data from or about a user under 18, please contact Change Ahead at: [email protected].

2. Identity of Data Controller

2.1 A data controller is a person or organisation who makes decisions about how your personal data is collected, used and handled.

2.2. We are the data controller and may be contacted
• By post at Homeless To Wellness Limited, Argyle House, Joel Street, Northwood, England, HA6 1LL; or
• By post at Change Ahead Non-Profit Charity, Argyle House, 76 Joel Street, Northwood, England, HA6 1LL; or
• by email at [email protected].

3. What personal data is collected

3.1 We collect personal data from and about users of our Platform (“Data”):
• directly from you when you provide it to us.
• automatically when you use the Platform.

3.2 We do not collect special categories of personal data such as information relating to or about the below or information about criminal records.
• Health
• Racial or ethnic origin
• Political opinions
• Membership of a political association, professional or trade association
• Membership of a trade union
• Religious beliefs or affiliations
• Philosophical beliefs
• Sexual orientation or practices
• Biometric information
• Criminal records

3.3 Data that you provide to us when you download, register with or use this Platform may include:
• First Name, Last Name
• Postal address
• E-mail address
• Telephone number
• Profile picture

3.4 In addition we may collect other information that is about you but individually does not identify you, such as age or gender.

3.5 This information may also include:
• Information that you provide by filling in forms on the Platform such as first name, last name, email address, telephone number and address (“Contact Information”). This includes information provided at the time of registering to use the Platform and requesting further services.
• We may also ask you for information when you enter a contest or promotion sponsored by us, such as your Contact Information.
• Information you provide to us when you complete user surveys or surveys for research purposes such as your Contact Information.
• Information you provide to us when you report a problem with the Platform such as your first name, last name and email address.
• Records and copies of your correspondence (including e-mail addresses and phone numbers), if you contact us.
• Details of transactions you carry out through the Platform and of the fulfilment of your orders.
• Your correspondence within the Platform with other users (your username and location).

3.6 Third-party Information Collection

3.6.1 When you use the Platform or its content, certain third parties may use automatic information collection technologies to collect information about you or your device.

These third parties may include:
• Advertisers, ad networks and ad servers.
• Analytics companies.
• Your mobile device manufacturer.
• Your mobile service provider.

3.6.2 These third parties may use tracking technologies to collect Data about you when you use the Platform. The personal data they collect may be associated with your Data or they may collect information about your online activities over time and across different websites, apps and other online services or websites. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

3.6.3 We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

3.6.4 For information about how you can opt out of receiving targeted advertising from many providers see section 8, “What choices you have with respect to how personal data is used”.

4. How Data is collected.

4.1 Automatic Data collection and tracking.

4.1.1 When you download, access and use the App, it may use technology to automatically collect:
• Usage details. When you access and use the Platform, we may automatically collect certain details of your access to and use of the Platform, including traffic data, location data, logs and other communication data and the resources that you access and use on or through the Platform.
• Device information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.
• Stored information and files. The Platform also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts and address book information. You will be asked for your consent to such access and use of your personal data within the Platform. You can withdraw your consent at any time via the settings menu.
• Location Information. This Platform collects real-time information about the location of your device. We do not, however, continually collect user location data nor do we collect location data without the user being aware. We store the location of a user at set points for example when you choose to update your location and when you create/edit an item. Some of our location-enabled Services require your personal data for the feature to work. You will be asked for your consent to such access and use of your personal data within the Platform. Note, however, that opting out of the Platform’s collection of location information will cause its location-based features to be disabled. You can withdraw your consent at any time via the settings menu.

4.2 If you do not agree to us collecting this information, please do not create an account with us.

4.3 We may also use these technologies to collect information about your activities over time and across third-party websites, apps or other online services (behavioural tracking).

4.4 The technologies we use for automatic Data collection may include:
• Cookies (or mobile cookies). A cookie is a small file placed on your smartphone or device. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone or device. However, if you select this setting you may be unable to access certain parts of our Platform. The cookies we use include:
(a) Strictly necessary cookies: these are required for the operation of our Platform. They include, for example, cookies that enable you to log into secure areas of our Platform.
(b) Analytical/performance cookies: these allow us to recognise and count the number of visitors on and to see how visitors move around the Platform when they are using it. This helps us to improve the way our Platform works, for example, by ensuring that users are finding what they are looking for easily.

These cookies are used to collect information about how visitors use our Platform. We use the information to compile reports on general user traffic, conversion statistics and to help us improve the site. The cookies collect information anonymously.

Please note that our advertisers may also use cookies, over which we have no control.
• Web Beacons: pages of the Platform and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related platform statistics (for example, recording the popularity of certain platform content and verifying system and server integrity).
• Functionality cookies: these are used to recognise you when you return to our Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). By using the Platform, you agree to our placement of functionality cookies.
• Targeting cookies: these record your visit to our Platform, the pages you have visited and the links you have followed. We will use this information to make our Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
• Third Party Cookies: the Platform may link to other websites owned and operated by certain trusted third parties (for example Facebook) who, for example, collect data that helps us to track conversions from Facebook ads. These other third-party websites may also use cookies or similar technologies in accordance with their own separate policies. Please note that our advertisers may also use cookies, over which we have no control. For privacy information relating to these other third-party websites, please consult their policies as appropriate.

4.5 Third party software/services

4.5.1 We use the following third-party software/services to collect and process your personal data for the following reasons:
• CHATRA: chat module collects user data
• Google Analytics: Feature usage and acquisition channel reporting
• Facebook: Acquisition channel reporting

5. How we use Data and lawful basis for processing

5.1 Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Platform. Specifically, we use your Data to:
• To set up and operate your Change Ahead account (such processing is necessary for the performance of our contract with you).
• To verify your identity and carry out security checks in order to set up your account (such processing is necessary for the performance of our contract with you and necessary for us to comply with a legal obligation).
• Provide you with the Platform and its contents, and any other information, products or services that you request from us (such processing is necessary for the performance of our contract with you).
• Give you notices about your account, including expiration and renewal notices (such processing is necessary for the performance of our contract with you and necessary for us to comply with a legal obligation).
• Ensure that content from our Platform is presented in the most effective manner for you and for your computer or device for accessing the Platform (such processing is necessary for the performance of our contract with you).
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection (such processing is necessary for our legitimate interests (to recover monies due etc).
• Notify you when Platform updates are available, and of changes to any products or services we offer or provide though it (such processing is necessary for our legitimate interests (to allow us to provide changes to our software, products or services)).
• To collect information from surveys that you sign up to take part in (such processing is necessary for our legitimate interests (to improve our services)).
• To manage your account and providing notifications, should this service be introduced within the Platform (such processing is necessary for the performance of our contract with you and is necessary for our legitimate interests (to process payments)).
• To administer the Platform and for internal operations, including trouble shooting, data analysis, testing, research, statistical and survey purposes.
• to give you, or allow certain third parties to give you, information about services we feel may be of interest to you.
• for the transmission by email of marketing materials that may be of interest to you;
• to contact you for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the Platform, in each case, in accordance with this privacy policy.

5.2. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see section 9 below).

5.3. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:
• soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular service, and we are marketing similar services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
• for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide in the registration process.

5.4. If you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time.

5.5. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract

5.6 The usage information we collect helps us to improve our Platform and to deliver a better and more personalised experience by enabling us to:
• Estimate our audience size and usage patterns (such processing is necessary for our legitimate interests (for running our services and to study how users use our Platform).
• Store information about your preferences, allowing us to customize our Platform according to your individual interests (such processing is necessary for our legitimate interests (for running our services).
• Speed up your searches (such processing is necessary for our legitimate interests (for running our services).
• Recognise you when you use the Platform (such processing is necessary for the performance of our contract).
• To provide us with information about how the Platform is running or whether there are any faults or issues with our products and services (such processing is necessary for our legitimate interests (for us to deliver a better service to you).

5.7 We use location data:
• To provide information about services that meet the user’s requirements within a fixed distance from the user’s set location (such information is necessary for the performance of our contract with you).
• To allow others to receive information about a user’s service requirements within their search radius (such information is necessary for the performance of our contract with you).

6. Keeping Data

6.1 We have implemented reasonable measures designed to secure your Data from accidental loss and from unauthorised access, use, alteration and disclosure for example:
• access to your account is controlled by a password and a username that is unique to you.
• we store your Data on secure servers.

6.2 The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Platform like message boards. The information you share in public areas may be viewed by any user of the Platform.

6.3 Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your Data, we cannot guarantee the security of your Data transmitted through our Platform. Any transmission of Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

6.4 If you suspect that there has been a breach of the security of your data you should contact Change Ahead at: [email protected] and include details of:
• the nature of the breach
• the date of the breach
• the full circumstances of the breach.

6.7 On notification of such a breach we will investigate the matter and, where appropriate and required by law, notify the relevant data protection regulator.

7. How personal data is shared and with whom.

7.1 You may provide information to be published or displayed (“Posted”) on public areas of the Platform (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. We cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorised persons.

7.2 We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

7.3 In addition, we may disclose personal information that we collect or you provide:
• to our subsidiaries and affiliates.
• to contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep Data confidential and use it only for the purposes for which we disclose it to them.
• to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Data held by the Company about our Platform users is among the assets transferred.
• to fulfil the purpose for which you provide it. For example, if you give us an e-mail address to use the “e-mail a friend” feature of our Platform, we will transmit the contents of that e-mail and your e-mail address to the recipients.
• for any other purpose disclosed by us when you provide the information.
• for the purposes of academic research.
• for any other purpose with your consent.
• to comply with any court order, law or legal process, including to respond to any government or regulatory request.
• to enforce our rights arising from any contracts entered into between you and us.
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

8. What choices you have with respect to how personal data is used.

8.1 We strive to provide you with choices regarding the Data you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information. You may need to adjust the settings on your device to restrict the collection of information by the Platform but this may prevent you from accessing all of the features of the Platform.
• Tracking Technologies: You may be able to set your browser or device to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Platform may then be inaccessible or not function properly.
• Location Information: You can choose whether or not to allow the Platform to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Platform may then be inaccessible or not function properly. For example, users have the ability to only allow manual geolocation (rather than using their device’s auto-locating functionality), the provision of at least one piece of location data (i.e. their search location) is a requirement for the Platform to function.
• Promotion by the Company: If you do not want us to use your e-mail address or other contact information to send you information, notifications, news, surveys or promote services, you can opt-out by logging onto the Platform and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an e-mail stating your request to [email protected].
• Targeted Advertising by the Company: We do not use information that we collect or that you provide to us to deliver advertisements.
• Disclosure of your information for third-party advertising and marketing: We do not share your Data with third parties for advertising and marketing purposes. However, we may include offers from third parties in our marketing materials.

8.2 We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. (Note: In the United States of America you can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website).

9. Your rights with respect to personal data.

9.1 You have the following rights in relation to your Data:
• Right to access: the right to request copies of the Data we hold about you at any time. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
• Right to correct: the right to have your Data rectified if it is inaccurate or incomplete.
• Right to erase: the right to request that we delete or remove your Data from our systems.
• Right to restrict our use of your Data: the right to “block” us from using your Data or limit the way in which we can use it.
• Right to data portability: the right to request that we move, copy or transfer your Data.
• Right to object: the right to object to our use of your Data, including where we use it for our legitimate interests.

9.2 To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data, please contact us via this e-mail address: [email protected].

9.3 If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/

9.4. We will respond to a request to access, correct or delete any data within 30 days of the date we receive the request.

9.5. We may not accommodate a request to change information if we believe the change would violate or breach any law or legal requirement or cause the information to be incorrect.

9.6. If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Platform users. Proper access and use of information provided on the Platform, including User Contributions, is governed by our Terms and Conditions.

10. How long personal data is kept.

10.1 Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted.

10.2. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

10.3. Upon deletion of an account, all Data will be removed as soon as possible, and always within 90 days of the deletion.

11. Changes to this privacy policy

11.1 We may update our privacy policy from time to time. If we make material changes to how we treat our users’ Data, we will notify you by email or via the App. By continuing to use the App after notification, you will be deemed to have accepted any changes.

11.2. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.

12. Enquiries regarding this privacy policy

12.1 All questions, comments and requests regarding this privacy policy should be addressed to the contact details as set out on the Platform and on www.changeahead.org.uk or by e-mail to [email protected].

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