Our Policies
Safeguarding - Consent and Data
Data Legislation
In using any digital tools COLOURFUL PEACH should be able to demonstrate compliance with GDPR rules, especially in regards to collecting data from young people as detailed below.
Colourful Peach is required to abide by General Data Protection Regulation (GDPR) as it applies in the UK, tailored by the Data Protection Act 2018.
Definition of an Information Society Service (ISS)
GDPR defines this as “any service normally provided for remuneration, at a distance, by electronic means and at the individual request of a recipient of services.”
For the purposes of this definition:
(i) ‘at a distance’ means that the service is provided without the parties being simultaneously present;
(ii) ‘by electronic means’ means that the service is sent initially and received at its destination by means of electronic equipment for the processing (including digital compression) and storage of data, and entirely transmitted, conveyed and received by wire, by radio, by optical means or by other electromagnetic means;
(iii) ‘at the individual request of a recipient of services’ means that the service is provided through the transmission of data on individual request.
Article 8 of the GDPR
Where an organisation offers an Information Society Service (ISS) ISS directly to children Article 8 of the GDPR (as implemented in the UK) provides that:
· only children aged 13 years and over may lawfully provide their own consent for the processing of their personal data;
· an adult with parental responsibility must provide consent for processing if the child is under 13; and
· in such cases you must make reasonable efforts, taking into consideration available technology, to verify that the person providing parental consent does, in fact, hold parental responsibility for the child.
When collecting personal data in line with Article 8 then the organisation make sure that the process is in accordance with all the requirements of the GDPR. This includes:
· minimising the data that is collected;
· not retaining it beyond the time that it is needed; and
· adequately protecting it.
Data gathering
Transparency is key to gaining informed consent from parents/ guardians for a young person to attend a programme either in person or online. As an organisation we need to ensure that we raise children’s (and their parents’/carers’) awareness of data protection risks, consequences, safeguards and rights by:
· telling them what we are doing with their personal data;
· being open about the risks and safeguards involved; and
· letting them know what to do if they are unhappy.
Data Safety
The organisation should complete checks on the suitability of technology to be used to store data or a tool for virtual programmes. Using online tools for virtual programmes requires checks to ensure safe use by young people including the following steps:
· Research of the technology and how it uses data in of itself, as well as accessibility to the technology
· Complete a Data Protection Impact Assessment
· Check what Consent permissions will be required
School Programmes
For all face to face programmes delivered either at the school’s site or at a venue consent is gained from the school for students to attend. The school would hold all medical and next of kin details for the programmes, which means no collection and storage of data by COLOURFUL PEACH is required.
Safeguarding responsibility for this form of delivery remains with the School and Colourful Peach would ensure their policies are followed, as well as following usual reporting for any Colourful Peach programme.
Privacy policy
Colourful Peach Ltd (“us”, “we”, or “our”) operates the https://www.colourfulpeach.com website.
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://www.colourfulpeach.com
Definitions
Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies
Cookies are small pieces of data stored on a User’s device.
Data Controller
Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
For the purpose of this Privacy Policy, we are a Data Controller of your data.
Data Processor (or Service Providers)
Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject
Data Subject is any living individual who is the subject of Personal Data.
User
The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
Email address
First name and last name
Phone number
Address, Post code, City
Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
Usage Data
We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.
Use of Data
Colourful Peach Ltd uses the collected data for various purposes:
· To provide and maintain our Service
· To notify you about changes to our Service
· To allow you to participate in interactive features of our Service when you choose to do so
· To provide customer support
· To gather analysis or valuable information so that we can improve our Service
· To monitor the usage of our Service
· To detect, prevent and address technical issues
· To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Retention of Data
Colourful Peach Ltd will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Colourful Peach Ltd will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Disclosure Of Data
Disclosure for Law Enforcement
Under certain circumstances, Colourful Peach Ltd may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal Requirements
Colourful Peach Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:
To comply with a legal obligation
To protect and defend the rights or property of Colourful Peach Ltd
To prevent or investigate possible wrongdoing in connection with the Service
To protect the personal safety of users of the Service or the public
To protect against legal liability
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Your Rights
Colourful Peach Ltd aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the right:
· To access and receive a copy of the Personal Data we hold about you
· To rectify any Personal Data held about you that is inaccurate
· To request the deletion of Personal Data held about you
· You have the right to data portability for the information you provide to Colourful Peach Ltd.
You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.
Please note that we may ask you to verify your identity before responding to such requests.
Analytics
We may use third-party Service Providers to monitor and analyse the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Behavioural Remarketing
Colourful Peach Ltd may use remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.
Google AdWords
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation
Pinterest remarketing service is provided by Pinterest Inc.
You can opt-out from Pinterest’s interest-based ads by enabling the “Do Not Track” functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data
You can learn more about the privacy practices and policies of Pinterest by visiting their Privacy Policy page: https://about.pinterest.com/en/privacy-policy
Links To Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Children’s Privacy
Our Service does not address anyone under the age of 11 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 11. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Changes To This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us:
By email: team@colourfulpeach.com
Policies last reviewed by: Ella Simms and Katherine Li October 2021. Next review date: 18th April 2022.