INTRODUCTION

We are Living Streets (the Pedestrians’ Association), a charitable company limited by guarantee (company number 5368409). Under EU data protection law, we are a ‘controller’, which means that we collect information about you when you engage with us and we determine how that information is used. This Privacy Policy describes Living Streets’ policies and procedures on the collection, use and disclosure of your personal information, including cookies; our use of cookies; and how you may reject such cookies. Whenever we obtain your personal information, we will treat that information in accordance with this policy and in accordance with the law.

The provision of your personal information to us is voluntary. However, without providing us with your personal information, your use of our services or your interaction with us may be impaired. For example, you will be unable to access our members’ services.

If you are using or looking to use our travel tracker application, please refer to our supplementary policy available at the foot of this policy, in addition to this main privacy policy.

By accessing the Living Streets website or Living Streets owned websites and providing your information you indicate your acceptance of this Privacy Policy.

USE OF YOUR PERSONAL INFORMATION

We collect personal information about you when you provide it to us directly (eg to sign up to receive our newsletter, to make purchases from our online shop, to participate in online campaigns (eg petitions or other actions) or to  register for events), and indirectly when you visit our website (please see the ‘visiting our website’ section below). When we obtain your personal information we have legal obligations towards you when we use your  information

We collect, store and otherwise process personal information about you if and when you  provide personal information to Living Streets to log your walks, to take campaign actions, to receive information, to purchase products, to make a donation, to receive information about or become involved in promotions or other initiatives undertaken by Living Streets and visit our website. This personal information may include details such as your name, address, mobile number, email address, your journey details or the amount you have donated. Living Streets requires your name in order to indicate your ranking within your area on our travel leaderboards.

The personal information we collect about you may be used by Living Streets for the following purposes:

  • to provide you with services, products or information you have requested
  • to address emails correctly
  • to determine who you r MP, councillor or other representative is when you opt to take part in an online campaign action
  • to process your donations
  • to monitor the service we provide to you
  • to provide you with information or other communications about Living Streets
  • to display on our Travel Tracker site your ranking within leaderboards
  • to satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/ or law enforcement bodies with whom we may work (for example requirements relating to the payment of tax or anti-money laundering);
  • for the prevention of fraud or misuse of services; and/or for the establishment, defence and/ or enforcement of legal claims.

The GDPR requires us to rely on one or more lawful bases to use your personal information. We consider the grounds listed below to be relevant:

  1. Where you have provided your consent for us to use your personal information in a certain way (for example, we will ask for your consent to use your personal information to send you fundraising material by email, and we may ask for your explicit consent to collect special categories of your personal information).
  2. Where necessary so that we can comply with a legal obligation to which we are subject (for example, where we are obliged to share your personal information with regulatory bodies which govern our work and services).
  3. Where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract (for example, if you apply to work for/ volunteer with us).
  4. Where it is in your/ someone else’s vital interests (for example, in case of medical emergency suffered by a beneficiary).
  5. Where there is a legitimate interest in us doing so.

The GDPR allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights).

In broad terms, our “legitimate interests” means the interests of running Living Streets as a charitable entity and pursuing our aims and ideals such as achieving a better walking environment and inspiring people to walk more.

When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).

If you choose to provide your personal details to Living Streets you agree that your personal information may be displayed as set out above.

Other than for the purposes described above, Living Streets will not use your personal information without your prior consent.

If you are notified on a Living Streets site that your information may be used to allow Living Streets to contact you for "service administration purposes", this means that Living Streets may contact you for a number of purposes related to the service you have signed up for. For example, we may wish to provide you with password reminders or notify you that the particular service has been suspended for maintenance.

We will not contact you for promotional purposes, such as notifying you of improvements to the service or new services on Living Streets unless you specifically agree to be contacted for such purposes at the time you submit your information on the site, or at a later time if you sign up specifically to receive such promotional information.

DISCLOSURE OF AND SHARING YOUR INFORMATION

In general, any information you provide to Living Streets will only be used within Living Streets and by its agents and service providers.

Your information will only be disclosed where we are obliged or permitted by law. If you post or send offensive, inappropriate or objectionable content anywhere on or to Living Streets or otherwise engage in any disruptive behaviour on Living Streets, Living Streets can use whatever information that is available to it about you to stop such behaviour. This may involve informing relevant third parties such as your employer, school, e-mail/Internet service provider and law enforcement agencies about the content and your behaviour.

RETENTION OF YOUR INFORMATION

Unless still required in connection with the purpose(s) for which it was collected and/or processed, we will remove your personal information from our records six years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure, we will remove it from our records at the relevant time.

If you request to receive no further contact from us, we will keep some basic information about you on our suppression list in order to comply with your request and avoid sending you unwanted materials in the future.

We will ensure that all personal information supplied is held securely, in accordance with the Data Protection Act 1998 and current data protection guidance.

visiting our website

During the course of any visit to Living Streets, the pages you see, along with a short text file called a 'cookie', are downloaded to your computer. Many websites do this, because cookies enable website publishers to do useful things like find out whether the computer (and probably its user) has visited the website before. Our website displays a banner, asking for your consent to use cookies like these.

This is done on a repeat visit by checking to see, and finding, the cookie left there on the last visit. Living Streets will make no attempt to identify individual users to its website where users have not supplied personal information to Living Streets (eg for enews subscription). However, we use Google Analytics to monitor traffic to our site and we may use information collected by this tool, such as details of your service provider, for monitoring purposes. You may wish to prevent this information from being communicated; if so, please download the Google Analytics Opt-Out Browser Add-on (https://www.google.com/settings/ads/plugin).

Cookies currently used on the Living Streets website:

Analytics cookies (like _utma, _utmb, _ga etc) – used to collect Google Analytics data.

cb_enabled - a cookie that confirms acceptance of cookies and hides the approval requested by users.

Third party vendors, including Google, show Living Streets ads on sites on the internet. They also use cookies to serve ads based on a user's prior visits to the Living Streets website. You may wish to opt out of Google's use of cookies by visiting the Google advertising opt-out page.

Through the Hotjar tracking code the information collected includes:

Device-specific data

The following information may be collected through your device and browser:

o your device's IP address (collected and stored in an anonymized format);
o your email address including first name and surname;
o device screen size;
o device type (unique device identifiers) and browser information;
o geographic location (country only);
o preferred language used to display the webpage.

Log data

Our servers automatically record information which is created upon using Hotjar. Data
includes:

o referring domain;
o pages visited;
o geographic location (country only); 
o preferred language used to display the webpage;
o date and time when website pages were accessed;

Hotjar will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Hotjar uses a variety of services hosted by third parties, such as Google Analytics and Optimizely. These services may collect information sent by your browser as part of a web page request, such as cookies or your IP request. For information on how Google Analytics and Optimizely collect and use your information, please refer to their privacy policies. By continuing to use this website, you consent to the processing of the above data by Hotjar and by the third parties used by Hotjar in accordance with their respective privacy policies. The cookies used by Hotjar have differing durations; some are 365 days, some persist for the session only.

To opt out please go to this link.

WHAT IS A COOKIE?

A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your browser from a website's computer and stored on your computer's hard drive. Each website can send its own cookie to your browser if your browser's preferences allow it, but (to protect your privacy) your browser only permits a web site to access the cookies it has already sent to you, not the cookies sent to you by other sites.

Many sites do this whenever a user visits their website in order to track online traffic flows. Cookies record information about your online preferences. Users have the opportunity to set their computers to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these, of course, means that certain personalised services and member only content cannot then be provided to that user and accordingly you may not be able to take full advantage of all of Living Streets features.

Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences. If you have set your computer to reject cookies you can still browse Living Streets anonymously until such time as you wish to register for Living Streets services. For further information on cookies please visit http://www.aboutcookies.org.

TYPES OF COOKIE

There are essentially two types of cookie. "Session" cookies and "persistent" cookies. Session cookies carry essential data from page to page during a unique visit to a site. When you close your browser or if you are inactive on the site for a period of more than 30 minutes, your computer will automatically delete any session cookies placed on your computer.

This site uses session cookies. If you are not a member of the site, only one session cookie is used and it tells the site that you are not an authenticated member of the site. If you are a member of the site and have logged in, there are more session cookies placed on your computer which maintain your login status and save your username and password temporarily.

Persistent cookies carry information between visits to a site. Some sites use persistent cookies to track your behaviour within a site, or they allow 3rd parties to place cookies on your machine when adverts are viewed. You may be told that this enables the advertising delivery agencies to better tailor the adverts they deliver to your areas of interest. This site DOES NOT use persistent cookies in this way. For visitors who are not members, only one cookie is saved to your computer, which records the date and time of the last page you viewed within the site.

If you are a site member, you have the option of saving your login details such that you can be automatically logged in on your next visit. This feature is entirely optional.

SECURITY OF YOUR INFORMATION

Living Streets takes reasonable steps to ensure the security of all information it collects, including that the information is protected from misuse and loss and from unauthorised access, modification or disclosure. This includes financial details related to donations which are processed by third party providers. 

Your personal information is maintained in a secure environment, which can be accessed only by authorised personnel. However, no data transmission over the internet or information stored on servers accessible through the internet can be guaranteed to be fully secure, therefore any donations or purchases you make through our website are at your own risk. 

exercising your RIGHTS

Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for marketing or fundraising purposes or to unsubscribe from our email list at any time. You also have the following rights:

  1. Right of access – you can write to us to ask for confirmation of what personal information we hold on you and to request a copy of that personal information. Provided we are satisfied that you are entitled to see the personal information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exemptions that apply.
  2. Right of erasure – at your request we will delete your personal information from our records as far as we are required to do so. In many cases we would propose to suppress further communications with you, rather than delete it.
  3. Right of rectification – if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated. You can also ask us to check the personal information we hold about you if you are unsure whether it is accurate/up to date.
  4. Right to restrict processing – you have the right to ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage.
  5. Right to object – you have the right to object to processing where we are (i) processing your personal information on the basis of the legitimate interests ground, (ii) using your personal information for direct marketing or (iii) using your information for statistical purposes.
  6. Right to data portability – to the extent required by the GDPR, where we are processing your personal information (that you have provided to us) either (i) by relying on your consent or (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contact, and in either case we are processing using automated means (i.e. with no human involvement), you may ask us to provide the personal information to you – or another service provider – in a machine-readable format.
  7. Rights related to automated decision-making – you have the right not to be subject to a decision based solely on automated processing of your personal information which produces legal or similarly significant effects on you, unless such a decision (i) is necessary to enter into/perform a contract between you and us/another organisation; (ii) is authorised by EU or Member State law to which we are subject (as long as that law offers you sufficient protection); or (iii) is based on your explicit consent.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing personal information requested to you. 

Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you contact us.

You are further entitled to make a complaint about us or the way we have processed your personal information to the data protection supervisory authority in your home country. In the UK, the data protection authority is the Information Commissioner’s Office – www.ico.org.uk. For further information on how to exercise this right, please contact us

Please address requests to exercise your rights above or find out more to our data protection contact at Living Streets, 4th Floor, Universal House, 88-94 Wentworth Street, London, E1 7SA (Email: info@livingstreets.org.uk)

USERS 16 AND UNDER

If you are aged 16 or under, you must get your parent/guardian's permission beforehand

CHANGES TO OUR PRIVACY POLICY

Significant changes to this policy will be communicated on this webpage.

CONTACT

All comments, queries and requests relating to our use of your information are welcomed and should be addressed to info@livingstreets.org.uk

 

SHARING CONTENT WITH LIVING STREETS

By uploading content onto Living Streets owned websites, you agree, understand and/or confirm that:

  • you grant Living Streets free of any charge, an unrestricted and unlimited non-exclusive licence to display, use, reproduce, modify, adapt, publish, and distribute that content;
  • Living Streets may use the content in connection with its various activities and charitable purposes such as publications, presentations, talk/event materials, websites or marketing materials, products and national/local press for publicity promotion and/or campaign purposes;

  • The content you upload is your own original work (and that you have all necessary rights to provide the content to Living Streets upon these Terms and Conditions), is not defamatory and does not infringe any English law or the law of any country from which the content is uploaded and that you have the consent of any persons who are identifiable in your content and if those persons are under 18 you have the consent of their parent or guardian;

  • The content you upload is not obscene, offensive, hateful or inflammatory, does not promote violence or discrimination based on race, sex, religion nationality, disability, sexual orientation or age, or is not likely to harass, upset, embarrass, alarm or annoy any other person;

  • You will not hold the charity liable for any damage caused by the use or inability to use the content and from any claims concerning the recording, upload, publishing or use of the content that have been breached by you. You are responsible for any challenges from a third party concerning copyright or other intellectual property ownership relating to the content; and the content does not contain computer damaging material, such as a virus or the like and you understand that the charity cannot provide insurance or financial cover in any event for loss or damage of any content provided to it.

  • The charity, at its sole discretion, reserves the right to refuse any content and to remove any content at any time from the website. Please do not upload any content for which you do not own the copyright.

RESTRICTIONS ON USE

This site is owned and operated by Living Streets. The material on this site is protected by international copyright and trademark laws. You may not modify, copy, reproduce, republish, upload, post, transmit, or distribute in any way any material from this site including code and software except as otherwise detailed. You may download material from this site for your personal, non-commercial use only, provided you keep intact all copyright and other proprietary notices.

DISCLAIMER

Living Streets may have provided links and pointers to Internet sites maintained by third parties. Living Streets does not operate or control in any respect any information, products or services on these third-party sites.

The materials on this site and the third-party sites are provided "as is" and without warranties of any kind either expressed or implied. To the fullest extent permissible pursuant to applicable law, Living Streets disclaims all warranties, expressed or implied, including, but not limited to, implied warranties of merchantability and fitness for a particular purpose.

Living Streets does not warrant that the functions contained in the materials will be uninterrupted or error-free, that defects will be corrected, or that this site, or the server that makes it available, are free of viruses or other harmful components. Living Streets does not warrant or make any representations regarding the use or the results of the use of the materials in this site or in third-party sites in terms of their correctness, accuracy, timeliness, reliability, or otherwise. You (and not Living Streets) assume the entire cost of all necessary maintenance, repair, or correction.

LIMITATION OF LIABILITY

Under no circumstances, including, but not limited to, negligence, shall Living Streets be liable for any direct, indirect, incidental, special or consequential damages that result from the use of, or the inability to use, Living Streets materials. If you are dissatisfied with any Living Streets material, or with any of Living Streets' terms and conditions, your sole and exclusive remedy is to discontinue using the Living Streets website.

TERMINATION

This agreement is effective until terminated by Living Streets, at any time without notice. In the event of termination, the disclaimers and limitations of liabilities set forth in this agreement, shall survive.

OTHER

This agreement shall be governed by and construed in accordance with the laws of the United Kingdom without giving effect to any principles or conflicts of law. If any provision of this agreement shall be unlawful, void or for any reason unenforceable, then that provision shall be deemed severable from this agreement and shall not affect the validity and enforceability of any remaining provisions.

 

WOW TRAVEL TRACKER – SUPPLEMENTARY PRIVACY POLICY

This policy is supplementary to our main privacy policy above, specifically for our WOW Travel Tracker tool.

Please ensure you have read our main privacy policy which applies to use of the travel tracker programme in addition to this supplementary policy.

Living Streets is committed to preserving the privacy of all visitors, and associated data. Please read the following supplementary policy to understand how we use and protect the information that you provide to us in relation to the WOW Travel Tracker.

INFORMATION THAT WE COLLECT FROM YOU

In addition to the information set out in our main privacy policy and its uses, when you visit or register with our online application, we may collect. We may also collect information about your usage of our online application, as well as information about you from messages you post to the online application and emails or letters you send to us.

Personal details which you enter during registration are for monitoring purposes only and will not be connected with individuals contact details.

USE OF YOUR INFORMATION

Information we collect will be used for the purposes set out in our main privacy policy (above). Additionally, your information collected in relation to the online application will enable us to provide you with access to relevant parts of the application. We will also use and analyse the information we collect so that we can administer, support, improve and develop the online application. In particular, we may use your information to contact you for your views on the online application and to notify you occasionally about important changes or developments to the online application. Further, where you have consented, we might also use your information to let you know by email about other events or updates that may be of interest to you. If you change your mind about being contacted, in the future, please let us know. You have a number of rights in relation to your data as set out in our main privacy policy [link].

USE OF TRAVEL DATA YOU HAVE PROVIDED

When using the online application to record how pupils have travelled, this will be recorded anonymously so that data cannot be associated with an individual child. Your school's data can be accessed by those in your school with access to the admin section of the online tool and can be analysed at aggregated class, year group and whole school levels. This data is also accessible by us, in an anonymised format, to help with our monitoring, evaluation and analysis of the walk to school intervention.

We may share your school's information and travel data with third parties for the purposes of evaluation and to measure the impact of the application and associated walk to school interventions, subject to our authorisation. Third parties may include evaluation agencies, local sector public bodies and UK government departments. We will not share any names or individual contact information of people at your school.

We may also use your travel data to help us promote the online application and our walk to school intervention, but we will only use information at school level, not class or individual level, unless authorised by your school.

DISCLOSURE OF YOUR AND YOUR SCHOOL'S INFORMATION

Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent. We will have access rights to your data, but will not have access to individual children's information, that can be linked back to that child. Individual children will not be able to be identified from the information entered, externally.

COOKIES

Cookies are small amounts of information which we may store on your computer. Unless you have indicated your objection when disclosing your details to us, our system will issue cookies to your computer when you log on to the online application. Cookies make it easier for you to log on to and use the online application during future visits. They also allow us to monitor online application traffic and to personalise the content of the online application for you. You may set up your computer to reject cookies by following the relevant instructions at www.aboutcookies.org. If you reject cookies, please be aware that you may not be able to use certain features on our online application.

SECURITY AND DATA RETENTION

We employ security measures to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. We will retain your information for a reasonable period or as long as the law requires.

ACCESSING AND UPDATING

You are entitled to see the information held about you and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date. If you wish to do this, please contact us at walktoschool@livingstreets.org.uk.

We are entitled by law to charge a fee of £10 to meet our costs in providing you with details of the information we hold about you.

CHANGES TO OUR PRIVACY POLICY

Any changes to our main privacy policy or to this supplementary information in the future will be posted to the online application and, where appropriate, through email notification to the address associated with your school's account.

CONTACT

All comments, queries and requests relating to our use of your information are welcomed and should be addressed to walktoschool@livingstreets.org.uk