AlphaGalileo privacy notice

The purpose of this notice

1. AlphaGalileo is committed to protecting your personal data. This privacy notice describes how we look after your personal data when you visit our website (regardless of where you visit it from); informs you of your privacy rights and how the law protects you. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

AlphaGalileo privacy basics

2. AlphaGalileo operates from a password protected web site that serves journalists and research public relations staff, who contribute news. Contact details of news contributors are only available to other logged in users: contributors, journalists and bloggers. The contact details of researchers or others who can provide background on content is placed in ‘Notes for Editors’ and is only available to logged in users. Journalists information is never disclosed to other users or third parties.

Data controller

3. AlphaGalileo Limited is the controller and is responsible for your personal data. AlphaGalileo is collectively referred to as "AlphaGalileo", "we", "us" or "our" in this privacy notice.

4. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

5. Our full details are: Full name of legal entity: AlphaGalileo Limited Data privacy manager: Paul Sibley, Finance Director Email address: paul.sibley@alphagalileo.org Postal address: Coppergate House, 16 Brune Street, London E1 7NJ

6. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

7. This version was last updated on 15 May 2018.

8. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

9. This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

10. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

11. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

(a)         Identity Data includes first name, last name, username or similar identifier and job title (if you choose to give this to us).

(b)         Contact Data includes email address, postal address (if you choose to give this to us) and telephone number (if you choose to give this to us).

(c)         Transaction Data includes details about payments to and from you and other details of services you have purchased from us.

(d)         Technical Data includes internet protocol (IP) address, your 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 this website.

(e)         Profile Data includes your username and password, purchases made by you, your interests and preferences. 

(f)          Usage Data includes information about how you use our website and services.

(g)         Communications Data includes your communication preferences.

Aggregated data

12. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Special Categories of Personal Data

13.    We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

14.    Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to the services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

How is your personal data collected?

15. We use different methods to collect data from and about you including direct interactions and automated technology or interactions.

Direct interactions

16. You may give us your Identity, Contact, Profile and Communications Data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

(a)         create an account on our website;

(b)         upload content to our website;

(c)         subscribe to our service;

(d)         request information to be sent to you; or

(e)         contact us about our website or service.

Automated technologies or interactions

17.  As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see the description of our cookies for further details.

How we use your personal data

18. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

(a)         Where we need to perform the contract we are about to enter into or have entered into with you.

(b)         Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

(c)         Where we need to comply with a legal or regulatory obligation.

19. Generally we do not rely on consent as a legal basis for processing your personal data. If we do require your consent for any processing activity we will explicitly ask you for it.

Purposes for which we will use your persoanal data

20. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

21.  Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

22. We do not use your personal data for marketing purposes and we do not share your personal data with any third party for such purposes. 

Opting out

23. You can ask us to stop sending you communications at any time by logging into the website and adjusting your preferences.

24. Where you opt out of receiving such communications, this will not apply to personal data provided to us for other purposes.

Cookies

25.    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see the descriptions of our cookies at the annex.

Change of purpose

26.    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact the data privacy manager <paul.sibley@alphagalileo.org>.

27.    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

28.    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of your personal data

29.    We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 22 above.

(a)    Service providers we use to help run our business, who provide IT and system administration services.

(b)    Third party payment providers

(c)    Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

(d)    HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.

(e)    Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

30.    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

31.    By registering to use our website as a contributor you understand and acknowledge that your Contact Data will be available to other users registered with us in accordance with our Terms of Use. However we will not disclose your personal data to any person or organisation not registered with us, except as set out at paragraph 30 above.

International transfers

32.    Our servers and web hosting facilities are situated in Strasbourg. We currently do not transfer any data outside of the European Economic Area. Should we need to do so in the future it will be in compliance with the General Data Protection Regulations (GDPR or any national implementing law) requirements for external transfer and our Privacy Policy will be updated accordingly.

Data security

33.    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.

34.    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?

35.    We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

36.    To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

37.    For further information on our retention periods please contact the data privacy manager at <paul.sibley@alphagalileo.org>.

Your legal rights

38.    Under certain circumstances, you have rights under data protection laws in relation to your personal data.

39.    You have the right to:

(a)    Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

(b)    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

(c)    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

(d)    Object to processing of your personal data 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 processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

(e)    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

(f)    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

(g)    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

40.    If you wish to exercise any of the rights set out above, please contact us at <paul.sibley@alphagalileo.org>.

No fee usually required

41.    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

42.    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

43.    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary lawful basis

44.    ‘Legitimate Interest’ means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

45.    ‘Performance of Contract’ means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

46.    ‘Comply with a legal or regulatory obligation’ means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Annex: Cookies used by AlphaGalileo website

There are two types of cookie. One type is benign. These are used to make access to a web site easier and to provide us with anonymous user data, for example the total times an item is opened, but not by whom.

The other cookie type is used to gather information for marketing.

AlphaGalileo only uses the benign type.

The seven cookies we use are described below.