Start Network is a company and charity registered in England and Wales with company registration number 09286835 and charity registration number 1159483. You can access the Terms & Conditions of our website here.
The processing of your personal information is carried out by Start Network who for the purposes of this Policy is the Data Controller.
HOW CAN YOU CONTACT US?
Data Protection Officer, Start Network, The Cursitor, 38 Chancery Lane, London WC2A 1EN, UK.
Emails are not always secure, and they may be intercepted or changed after they have been sent. Start Network does not accept liability for any damage or loss caused or suffered in connection with any such communications. The contents of emails reflect the author’s views and not necessarily those of the Start Network.
Please do not send Start Network any confidential, financial or other sensitive personal data, or information through email unless the appropriate security measures have been taken.
The information in emails is confidential, so if you have received one by mistake, please delete it without copying, using, or disclosing its contents.
WHY DO WE COLLECT INFORMATION?
Start Network takes a proactive approach to user privacy and ensures that adequate steps are taken to protect the privacy of its users. Information collected may be used to:
- Determine your location.
- Provide you with content tailored to your needs and interests.
- Monitor how the site is used so we can continually improve it.
Our Privacy and Cookie Policies consider several laws, including:
- the Data Protection Act 2018
- The Privacy, Data Protection and Electronic Communications Regulation (UK GDPR)
- the Privacy and Electronic Communications (EC Directive) Regulations 2003
- General Data Protection Regulation (EU) 2016/679
- Any other applicable national data protection legislation according to where you may reside.
Generally, our processing of your personal information as described in this Policy is allowed by these laws because we have a legitimate need to carry out the processing for the purposes described above. Some processing may also be necessary so that we can perform a contract with you or because it is required by law. We only use your information to send you marketing communications by email or text with your consent, and you can always opt out of receipt of marketing communications by post, or email, see section ‘How you can contact us’.
HOW DO WE COLLECT INFORMATION?
We may collect information about you whenever you interact with us. For example, when you contact the Start Network regarding our activities, register as a user on our Start Fund portal, subscribe to our newsletter, send or receive information, you specifically and knowingly provide us with your personal information.
We may also receive information about you when you interact with third parties with whom we work - but only if you have given them permission to share your information.
We may supplement what we know about you with information that is available to the public. For example, to ensure that our communication with you is relevant and tailored to your background and interests, we may collect information about you from publicly available sources either directly or through third-party subscription services or service providers. See section, 'How will we combine and analyse the information we collect about you?'
WHAT INFORMATION DO WE COLLECT?
When you contact us through other means or use our website, we may collect some or all of this information, depending on how you contact us or use the site. We monitor how people use our website, so we can improve it. However, you can use our website anonymously without giving us any information.
If you visit our website as a guest, we may record information about:
- The areas of the website you visit.
- The amount of time you spend on the site.
- Whether you are new to the site, or have visited it before.
- How you came to our website – for example, through an email link or a search engine.
- The type of device and browser you use.
We do this by using cookies, which you can learn more about in the ‘What are cookies’ section.
If you visit our website as a logged-in, registered user via our Start Fund portal, as well as the information you provide when registering, you will have the opportunity to provide additional data such as interests, profile picture, or additional contact details through your profile page.
HOW WILL WE COMBINE AND ANALYSE THE INFORMATION WE COLLECT ABOUT YOU?
We are committed to communicating with you using an approach that is right for you. This means that we carefully manage the communications we send you to ensure that we are contacting you in the most appropriate way and that we are not sending you unwanted communications. To do this, we may combine the information that we collect about you and analyse what we know about your interests, preferences, and the level of potential engagement. We may also use statistical analysis to analyse this data and understand the likelihood that you will be interested in or responsive to a campaign or message.
We may use third party service providers to assist us in this process. We enter into contracts with service providers that require them to comply with data protection laws and to ensure that they have appropriate controls in place to protect the security of your information.
For more information on how we work with service providers, please see ‘How will we disclose the information we have collected to outside parties?’.
You can opt out of your data being combined and analysed for marketing purposes by contacting Start Network. However, this may mean that you stop receiving marketing communications from us more generally.
We may collect aggregated or anonymous information when you visit our website or interact with our content. For example, we may collect information about the services you use and how you use them, like when you watch a video on YouTube, visit our website or view and interact with our advertisements and content. Please see our section, ‘Categories of Cookies we use’ for more detail.
HOW WILL WE DISCLOSE THE INFORMATION WE HAVE COLLECTED TO OUTSIDE PARTIES?
We will generally only share your information with a third party where we have told you we will do so. However, we may also need to disclose your information if required to do so by law, by a regulator or during legal proceedings. Sometimes we may use our Legitimate Interest to share data but, only where we have conducted a risk assessment to ensure such sharing does not override your fundamental rights and freedoms.
HOW LONG WILL WE HOLD YOUR PERSONAL INFORMATION?
We will hold your personal information on our systems for as long as is necessary for the relevant activity or if it is set out in any relevant agreement you enter into with the Start Network (including, but not limited to, any Terms and Conditions of Use for a website).
HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We take appropriate physical, electronic, and managerial measures to ensure that we keep your information secure, accurate, and up to date, and that we only keep it as long as it is reasonable and necessary.
We use appropriate physical and technical security measures to protect your personal information during electronic transmission and when it is stored. We also regularly train our staff in data protection awareness to ensure we do everything possible to secure your information.
For financial, technical and operational reasons, we may, on occasion, need to use a service provider outside the European Economic Area (EEA) – this may include a country which does not have the same level of data protection as in the United Kingdom. In such circumstances we will take appropriate measures to protect your information. These measures include, but are not limited to, the use of EU and UK Standard Contractual Clauses where data is processed in a non-EEA country or in the US. Where data is processed in the US, and in the absence of the Privacy Shield agreement, we will also undertake a risk assessment which may include measuring the effectiveness of State Law. Where Special Category data is concerned, we may also conduct a Data Protection Impact Assessment (DPIA). Such measures are regularly assessed and amended if required.
Personal data held by us may be transferred to:
Start Network associates
We may pass your information to our service providers, partners, professional advisers, associated organisations, and other relevant organisations which may share the aims and objectives of the Start Network.
Third party organisations that provide applications/functionality, data processing or IT services to us
We use third parties to support us in providing our services and to help provide, run, and manage our internal IT systems. For example, providers of information technology, cloud-based software service, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them.
Additionally, personal data held by us may also be transferred to:
Third party organisations that otherwise assist us in providing goods, services, or information.
Auditors and other professional advisers.
Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation.
Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
JOB APPLICANTS AND CURRENT AND FORMER EMPLOYEES
If you apply to work with us, we will only use the information you give us to process your application and to monitor recruitment statistics. If we want to disclose information to someone outside of Start Network – for example, if we need a reference, or need to get a ‘disclosure’ from the Criminal Records Bureau – we will make sure we tell you beforehand, unless we are required to disclose this information by law.
When recruiting for a post based in another country, Start Network will sometimes need to transfer your personal information to that country to progress the recruitment. It may be that that country does not provide the same level of data protection as in the UK.
If you are unsuccessful in your job application, we will hold your personal information for six months after we have finished recruiting for the post you applied for. After this date we will destroy or delete your information.
If you begin employment with us, we will put together a file about your employment. We keep the information in this file secure and will only use it for matters that apply directly to your employment. Once you stop working for us, we will keep this file for up to 7 years in accordance with the Employment Rights Act 1998. You can contact us to find out more about this.
Some roles we advertise may be based with a Start Network Grant Custodian.
If you apply for a job or volunteering opportunity, we will also collect information so we can assess your suitability for the role.
Please read our Employee Privacy Notice for more information.
WHAT ARE COOKIES?
Cookies are small files, typically of letters and numbers, downloaded onto a device when you access certain websites or emails, including the Start Network website.
Cookies allow a website to recognise your device and provide the user with a more tailored experience within the website.
For more information see: www.allaboutcookies.org.
TYPES OF COOKIES WE USE
There are two broad types of cookies - 'first party cookies' and 'third party cookies':
First party cookies are cookies that are served directly by the website operator to your computer and are often used to recognise your computer when it revisits that site and to remember your preferences as you browse the site. Basically, these are our cookies.
Third party cookies are served by a service provider on behalf of the website operator and can be used by the service provider to recognise your computer when you visit other web sites. Third party cookies are most used for web site analytics or advertising purposes.
In addition, cookies may be either 'session cookies' or 'persistent cookies'. Your computer automatically removes session cookies once you close your browser. Persistent cookies will survive on your computer until an expiry date specified in the cookie itself, is reached. We use both session and persistent cookies.
We have assessed our cookies based on the International Chamber of Commerce Cookie Guide (http://www.iccwbo.uk/pages/privacy).
CATEGORIES OF COOKIES WE USE
Strictly necessary cookies: These cookies are essential for the user to move around the website and to use its features, e.g. logging in to our Start Fund portal.
Performance cookies: These cookies collect information about how the user makes use of the site, e.g. which pages the user visits most. These cookies do not collect information that identifies the user.
Functionality cookies: These cookies remember choices made by or attributes of the user and enhance the features and content you experience during your visit to our website, e.g. language, appeals visited or user’s location. This cookie is also used to remember a user's preferences for a font size, or customisable parts of a web page.
Targeting or advertising cookies: These cookies collect information about the users' browsing habits. This may also include your use of social media sites, e.g. Facebook, etc. or how you interact with our website which then shows you relevant content elsewhere on the internet. NB. These may also be used to choose the advertisements that are displayed to you on our website and other websites.
THERE ARE FOUR CATEGORIES OF COOKIES WE USE
First, strictly necessary cookies: these cookies are essential for the user to move around the website and to use its features, e.g., logging in to our Start Fund portal.
Second, performance cookies: these cookies collect information about how the user makes use of the site, e.g., which pages the user visits most. These cookies do not collect information that identifies the user.
Third, functionality cookies: these cookies remember choices made by or attributes of the user and enhance the features and content you experience during your visit to our website, e.g., language, appeals visited, or user’s location. This cookie is also used to remember a user's preferences for a font size, or customisable parts of a web page.
Fourth, targeting or advertising cookies: these cookies collect information about the users' browsing habits. This may also include your use of social media sites, e.g., Facebook, etc. or how you interact with our website which then shows you relevant content elsewhere on the internet. Please note, these may also be used to choose the advertisements that are displayed to you on our website and other websites.
WHAT INFORMATION DO WE COLLECT USING COOKIES?
We may collect some, or all of the information available from cookies when you visit our website, depending on how you use it. We monitor how people use our website, so we can improve it. We collect this information anonymously.
However, you can choose to use our website anonymously without giving us any information. Please see the ‘Changing your cookie preferences’ section.
Areas of the website you visit;
The amount of time you spend on the site;
Whether you are new to the site, or have visited it before;
The country, region, city and/or borough associated with your IP address or device;
How you came to our website – for example, through an email link or a search engine;
The type of device and browser you use;
How you use the website and the quality of your experience, for example, we may track your bandwidth when viewing videos;
How you interact with our sign-up forms, for example, what you select as your
Any error messages that you receive on the site.
Some of our pages contain embedded content such as YouTube videos, Twitter feeds, Facebook likes or Google plus share, and you may receive cookies delivered from these websites. The Start Network does not govern the publication of third-party cookies. To understand more about their cookies and privacy statements, please visit the relevant sites.
We cannot be held responsible for the privacy of data collected by websites not owned or managed by Start Network, including those linked through our website.
If you do not want cookies to be stored on your PC it is possible to disable this function, though this may limit your experience of using the site.
HOW DO YOU DISABLE COOKIES?
If you are using Microsoft Internet Explorer and you wish to block the Start Network website cookies, you can perform the following:
On your browser tools menu, select ‘Internet Options’
Click on the ‘Privacy’ tab and then on the ‘Sites’ button
Type the following into the ‘Address of website’ field: “www.startnetwork.org”
Click on the ‘Block’ button
Click on the OK button
Other browsers have similar cookie management abilities in their preferences settings, please refer to your browser’s ‘Help’ facility.
Find more detailed information on disabling cookies from aboutcookies.org.
Although not through cookies, we do measure the success of the emails we send – so we know what subject lines and stories people liked the most. We receive this information anonymously; we do not share this information.
WEBSITE STATISTICS ANALYTICS
Google 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.
You can always opt-out of Google Analytics cookies by Google’s opt-out tool.
CAN YOU GAIN ACCESS TO YOUR PERSONAL INFORMATION?
To the extent applicable under the UK Data Protection Law, you may request a copy, or to have any inaccuracies corrected, of the personal information relating to you which is held by the Start Network by contacting Start Network in writing at:
Data Protection Officer, Start Network, WeWork Aviation House, 125 Kingsway, London WC2B 6NH. Email: DPO@startnetwork.org
We will use reasonable efforts to supply, correct or delete any personal information about you held by the Start Network, upon request.
HOW TO UPDATE YOUR INFORMATION OR CHANGE YOUR CONTACT PREFERENCES
If you want to update the information we hold for you, or you think any information we have about you is incorrect or incomplete, please get in touch as soon as possible. If you want to have your details removed from our marketing mailing lists, or to change your marketing preferences, please contact us - see section ‘How can you contact us.’
When you register with us, you are stating that you are over 16 years of age or are a minor acting with parental consent. You agree that any information you provide to us about yourself upon registration or at any time is true. See the Terms and Conditions of Use for more information.
We cannot be held responsible for the privacy of data collected by websites not owned or managed by the Start Network, including those linked through our website.
WHAT OTHER DATA PROTECTION RIGHTS DO YOU HAVE?
You can make a complaint or raise a concern about how we process your personal data by contacting us – see ‘how can you contact us’ section. In some circumstances, you have the right to object to our processing of your personal data, or to stop us from continuing to make active use of personal data that we retain in our records.
If you are not happy with how we have handled your complaint, you can contact the Office of the Information Commissioner, at: https://ico.org.uk/make-a-complaint/ which oversees the protection of personal data in the UK. If you reside outside of the UK, you may need to consult your local Data Protection Supervisory Authority
Alternatively, you may choose to contact the Information Commissioner directly about your complaint, regardless of whether you have raised it with us first. You also are entitled to request a copy of the personal information relating to you which is kept on file by Start Network (for which we may charge an appropriate fee if the request is excessive) by contacting us - see ‘how can you contact us’ section.
NOTIFICATION OF CHANGES TO THIS PRIVACY NOTICE
Last modified: May 2021