Privacy Policy
PRIVACY POLICY
This Privacy Policy sets out the basis on which any personal data we collect from you, or you provide to us, will be processed by us. Please read the following information carefully.
This website www.womensbusinesscentre.com (Site) is provided by Women’s Enterprise Scotland (CIC) a not-for-profit organisation, constituted as a Community Interest Company trading as Women’s Enterprise Scotland (WES), and www.womensbusinesscentre.com (“Women’s Enterprise Scotland”, “Women’s Business Centre”, “WES”, “WBC”, “we”, “us” or “our”) are committed to protecting the privacy of our members, potential members and users of our website. We want to provide a safe and secure user experience. We will ensure that the information you submit to us or which we collect, via various channels (including our website, through written correspondence including e-mail) is only used for the purposes set out in this policy.
Through this Privacy Policy we aim to inform you about the types of personal data we collect from members, the purposes for which we use the data and the ways in which the data is handled. We also aim to satisfy the obligation of transparency under the EU General Data Protection Regulation 2016/679 (“GDPR”), Data Protection Act 2018 and other relevant laws.
For the purpose of this Privacy Policy the data controller of personal data is Women’s Enterprise Scotland and is registered with the Information Commissioner as a data controller with registration number ZA746182
Our contact details are set out in the Contact Us section at the end of this Privacy Policy.
Please also see our Cookie Policy.
We operate a platform that allows our members to run crowdfunding campaigns, those members may also be separately legally responsible for the use of your information in connection with those campaigns.
Our members run crowdfunding campaigns from our Site and in doing so may collect personal information from you if you make contributions to their campaigns. Their use of that information during and after their campaign (e.g. to keep in contact with you about progress of their campaign and their achievements) are uses of your information which those members determine, independently of us. As a result, those members will be separate controllers of your personal information.
We refer to ‘campaign owners’, ‘backers’ and ‘contributions’ throughout this document. For more information regarding these, please see our Crowdfunding Terms and Conditions.
Use of your personal information
We use your personal information for a variety of reasons. We rely on different legal grounds to process your personal information, depending on the purposes of our use and the risks to your privacy. You will only receive unsolicited marketing communications from us if you have consented and can opt-out of receiving them at any time. We do not share your personal information with companies that would send their marketing to you.
We use your personal information in the following ways:
Where you have provided Consent
We may use and process your personal information for the following purposes where you have consented for us to do so:
to contact you via email with marketing information about our services, training opportunities and business; and
to use any personal data we access through the use of cookies (see our Cookie Policy for further details).
You may withdraw your consent for us to use your information in any of these ways at any time. Please see ‘Your rights over your personal information’ for further details.
We will use your personal information where this is necessary for the following purposes:
to register and set you up as a member on our Site;
to publish details of your crowdfunding campaigns and the rewards you wish to offer;
to process your contributions to campaigns and share your details with our payment processors so that payments can be made from you;
Where necessary to comply with our Legal Obligations
We will use your personal information to comply with our legal obligations:
to keep a record relating to the exercise of any of your rights relating to our processing of your personal information;
to perform anti-money laundering and related checks where the law requires these;
to anonymise, pseudonymise and destroy your personal information in accordance with our retention policies and data protection law;
to handle and resolve any complaints we receive relating to the services we provide.
Where necessary for us to pursue a Legitimate Interest
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:
Processing necessary for us to promote our business, brand and activities and measure the reach and effectiveness of our activity.
for analysis and insight conducted to inform our marketing strategies, and to enhance and your visitor experience;
to tailor and personalise our marketing communications based on your attributes;
to identify and record when you have received, opened or engaged with our website or electronic communications (please see our Cookie Policy for more information);
to send you emails about your membership, campaigns or your contributions;
to supply your details to a campaign owner where you have made a contribution to their campaign;
Processing necessary for us to support our members with their enquiries
to respond to correspondence you send to us and fulfil the requests you make to us.
Processing necessary for us to respond to changing market conditions and the needs of our users
to analyse, evaluate and improve our Site and other services so that your visit and use of our Site and other services and social media pages, are more useful and enjoyable (we will generally use data amalgamated from many people so that it does not identify you personally);
to undertake market analysis and research (including contacting you with surveys) so that we can better understand you;
for the purposes of developing new features on our Site.
Processing necessary for us to operate the administrative and technical aspects of our Site efficiently and effectively
to administer our Site and our social media pages and for internal operations;
for the prevention or detection of fraud and other criminal activities or to assist in the apprehension of offenders, including by sharing your personal information with the relevant partner(s);
to verify the accuracy of data that we hold about you and create a better understanding of you as an member or user;
for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access, including to archive, destroy, pseudonymise or anonymise your personal information;
to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
to inform you of updates to our terms and conditions and policies; and
for other general administration including managing your queries, complaints, or claims, and to send service messages to you.
Marketing communications:
If you give your consent, we may use your personal information to contact you by email to send you newsletters or to notify you with details of our services. If you do not wish to receive email communications from us, please inform us by using the unsubscribe link inside the email messages we send.
Crowdfunding campaign owners can access contact details for the backers relating to their campaigns. Any communications they send using these details will be sent solely based on their decisions and for which they will be acting as the controller of your personal information.
Right to Object
You have a legal right to object at any time to the use of your personal information for direct marketing purposes; and the processing of your personal information which is based on our legitimate interests, unless there are compelling legitimate grounds for our continued processing.
Online Privacy Practices
The following websites www.womensbusinesscentre.com and www.wescotland.co.uk, (“the Sites”) are operated by Women’s Enterprise Scotland (CIC) a company registered in Scotland, company registration number SC406892, whose registered office is located at 2 Atlantic Square, 31 York Street, Glasgow G2 8AS.
We are keen to strike a fair balance between your personal privacy and ensuring that you obtain full value from the services (“the Services”) that we may provide to you.
How and when we collect personal information about you
This is personal information about you that you give to us when:
submitting personal information via our Site
following us, interacting with us and posting on our social media pages including our official pages on Facebook, Instagram, X (formerly Twitter) and LinkedIn and other social media platforms
participating in surveys for research purposes
we interact with you at events
corresponding with us by phone, email or in another way.
This information is provided by you entirely voluntarily.
This includes information provided on the Site at the time of registering as a member, posting details of campaigns, using any of the communication tools we provide for our members, making contributions to campaigns on the Site and when generally using our Site. For example you may give us your personal information by filling in forms, uploading profile information and other content to the Site, managing your account online, engaging in correspondence with us by phone, email or otherwise and meeting with us at events (e.g. you may provide us with your business card). We may also ask you for information if you report a problem with our Site or when you exercise your legal rights.
The Information we collect about you
We may ask for your consent to use your contact details for future marketing purposes. You have the right to withdraw your consent at any time.
When users sign up as members, we ask them for:
Name: first name and last name
Email address
Business Name
Location
Sector
Turnover
Employees (not including yourself)
Year founded
Legal Structure
Year of Birth
Ethnic Group
Do you have a physical or mental disability?
What gender do you identify as?
If a Member Account is created on the website we will require a Username and password.
For crowdfunding campaigns:
Banking information to receive/send funds from/to you
Information relating to the occurrence, investigation or prevention of fraud
Information relating to your contributions and crowdfunding
When downloading a list of backers of their campaigns, campaign owners will see the address details of those members who contributed to their campaign. Please note that if you change your address after the campaign owner has downloaded this data (this usually happens once their campaign is completed) the details the campaign owner may become out of date – so we would recommend also contacting the campaign owner to inform them of a change to your contact details.
The campaign owner will be responsible for handling your information after they receive it from us.
Please note that our standard receipt emails and notifications about campaigns contain important financial information regarding your contribution and so cannot be turned off.
Details of your visits to our websites (including, but not limited to, traffic data and location data) whether this is required for our own purposes or otherwise, and the resources that you access.
In addition through Google Analytics we will look at aggregated data across a range of insights such as where they have come from, how many users have met certain determined ‘objectives’, how many users have downloaded certain content, how many users return, how many users view content according to certain criteria (advice, inspiration, blog etc).
We also have a contact form asking for name, email and a free-type area for a message.
If you contact us, we may keep a record of your email or other correspondence.
We may also view any personal information which you allow to be shared, such as the information you upload to the Site (such as your Crowdfunder profile), and information you share on third party social networks.
When you visit our social media pages we collect:
the information you post on those pages;
information regarding your interactions with the content we post; and
statistical information regarding all our followers’ activities (but from which we cannot identify you as we only have access to this information in aggregated form).
We process your personal information using social media platforms in a variety of ways, as follows:
Pages. We use your personal information when you post content or otherwise interact with us on our official pages Facebook, Instagram, Twitter, LinkedIn and other social media platforms. We also use the Page Insights service for Facebook, Instagram and LinkedIn to view statistical information and reports regarding your interactions with the pages we administer on those platforms and their content. Where those interactions are recorded and form part of the information we access through the Page Insights services, we and the relevant platform are joint controllers of the processing necessary to provide that service to us.
Single sign-on. Our Site incorporates a feature provided by social media and other digital service providers that allows you to log into your account on this Site using the same login you have already set up with those providers. This feature is known as a ‘single sign-on service’. Any use we make of the personal information we receive from the platform using this feature is processing for which we are the sole controller.
Data from your profile. When you use single sign-on services, you will be prompted to confirm that you are happy to share with us your email address and certain other personal information you hold with those providers.
The Legal Basis for Processing your Personal Information
Under GDPR, the main grounds that we rely upon in order to process personal information of our users are the following:
(a) Necessary for entering into, or performing, a contract – in order to perform obligations that we undertake in providing a service to you, or in order to take steps at your request to enter into a contract with us, it will be necessary for us to process your personal data;
(b) Necessary for compliance with a legal obligation – we are subject to certain legal requirements which may require us to process your personal data. We may also be obliged by law to disclose your personal data to a government agency, regulatory body or law enforcement agency;
(c) Necessary for the purposes of legitimate interests – either we, or a third party, will need to process your personal data for the purposes of our (or a third party’s) legitimate interests, provided we have established that those interests are not overridden by your rights and freedoms, including your right to have your personal data protected. Our legitimate interests include responding to requests and enquiries from you or a third party, optimising our website and customer experience, informing you about our products and services and ensuring that our operations are conducted in an appropriate and efficient manner;
(d) Consent – in some circumstances, we may ask for your consent to process your personal data in a particular way.
How long we will hold your information
We will retain your personal information for the time necessary to provide the Services we perform for you, or stated by the purposes outlined in this Privacy Policy.
In particular, we will store certain categories of your personal information for the following periods of time:
Category of Personal Data Storage time period
Marketing data on contacts 5 years
User login and member account information to provide access to our services After 5 years of account inactivity
Website and analytics data 2 years
Information (other than member account information) relating to campaigns/campaign owners including contribution amounts – For unsuccessful campaigns, 7 years from the date the campaign is closed. For successful campaigns, indefinitely (but please see exceptions below).
Information relating to backers (other than member account information) including contribution history – 7 years from the date the campaign is closed.
Identity documents – If we require these for financial or fraud verification purposes, 7 years. If we require these to share with our payment processors for client verification purposes, 6 months. If we require these to verify your identity for a request by you in connection with your rights over your personal information (see below), 2 years.
Social media handles – Until you stop following our social media account or page.
Marketing preferences – For as long as you have not opted-out and if you opt-out, indefinitely after we place you on our suppression list to ensure we respect your wishes.
Complaints and queries – 2 years, except where these relate to legal claims, in which case 7 years.
The only exceptions to the periods mentioned above are where:
you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further ‘Your rights in relation to your personal information’);
you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see further Your rights in relation to your personal information);
we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible;
we archive the information, in which case we will delete it in accordance with our deletion cycle; or
in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
How we share your Personal Information
We may disclose your personal information to relevant third parties who will supply services you requested, to Government bodies and other authorities to whom we are legally obliged to pass your data and to relevant third parties.
Trusted Third Parties
We will only share your personal information with trusted third parties where we have retained them to provide services that you have requested or for our legitimate business purposes, such as IT, website or professional support services.
If we or our organisation merges with or is acquired by another entity, we will share your personal information with the new owners of the entity and their advisors. If this happens, we will notify you of such an event.
Transfer of Information outside the EEA
Under the General Data Protection Regulation, we are required to tell you if we transfer or intend to transfer information which we hold on you to countries outside the European Economic Area (“EEA”). We currently do not transfer such information outside the EEA.
We may disclose your information to the following:
if you make a contribution to a campaign we will share details of your contribution and the information you have provided such as name and email address) with the Campaign owner –
for them to administer your contribution and reward (if applicable), and to contact you in connection with your contribution, reward or their campaign in accordance with our Terms
backers to allow them to identify the project owners responsible for the projects to which they contribution, in accordance with our Crowdfunding Terms and Conditions;
our third party service providers, agents and subcontractors (Suppliers) for the purposes of providing services to us or directly to you on our behalf, including the operation and maintenance of our Site.
Our Suppliers can be categorised as follows:
Accountants and legal and security advisers and consultants
Professional Services (Accountancy, Security & Legal)
Banks, payment processors and financial services providers
Finance (Banking & Payment Processing)
Business intelligence and performance services
IT (Business Performance)
Cloud software system providers, including database, email and document management/monitoring providers
IT (Cloud Services, Data Management, Data Analytics, Software Development, Hosting, Verifitcation)
Fraud and identity verification services
Social media platforms
Media (Social Media)
Website and data analytics platform providers, and website performance tools
Website and App developers
Website marketing, search and integration services
Website hosting services providers
File and data transfer providers
The Suppliers above are located in the United Kingdom, European Economic Area or the USA.
When we use Suppliers, we only disclose to them any personal information that is necessary for them to provide their services and only where we have a contract in place that requires them to keep your information safe and secure.
We may disclose the personal information to other third parties as follows:
if we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request, including by the police, courts, tribunals, regulators or similar authorities or if we voluntarily decide to cooperate with such authorities.
Visitors to our website
When someone visits www.womensbusinesscentre.com we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
Use of cookies and tracking technology
We use cookies (defined below) for collecting user information from the Sites. Cookies are messages given to a web browser by a web server. The message is then stored by the browser in a text file called cookie.txt. Each time the browser requests a page from the server, this message is sent back. A cookie’s main objective is to identify users and personalise their visit by customising web pages for them, for example by welcoming them by name next time they visit the same site.
We use cookies and tracking to understand how users use and behave on the Site.
Other websites which provide information about cookies and allow you to manage your privacy can be found at:
www.aboutads.info
optout.networkadvertising.org for US-based users
www.youronlinechoices.eu for users in the EU
More information regarding our use of cookies can be found in on our Cookie Policy.
E-mail campaign
We use a third party provider, Mailchimp, to deliver our e-mail campaigns. We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter. For more information, please see www.mailchimp.com
Internet based transfers
Given that the Internet is a global environment, using the Internet to collect and process personal data necessarily involves the transmission of data on an international basis. 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 via third party networks; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Links to other websites
Our sites contain links to and from the websites of our suppliers and other third parties. If you follow a link to any of these other websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or for these third party websites. This privacy notice does not cover the links within these sites linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
Your rights on the information we hold about you
You have certain rights in relation to personal information we hold about you. Details of these rights and how to exercise them are set out below. We will require evidence of your identity before we are able to act on your request.
Right of Access
You have the right at any time to ask us for a copy of the personal information about you that we hold. Where we have good reason, and if the GDPR permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reasons for doing so.
Right of Rectification
If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data rectified, updated or completed. You can let us know by contacting us.
Right of Erasure
In certain circumstances, you have the right to request that personal information we hold about you is erased e.g. if the information is no longer necessary for the purposes for which it was collected or processed or our processing of the information is based on your consent and there are no other legal grounds on which we may process the information.
Right to object to or restrict processing
In certain circumstances, you have the right to object to our processing of your personal information by contacting us. For example, if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which override your rights and interests. You also have the right to object to use of your personal information for direct marketing purposes.
You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy.
Right of Data Portability
In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.
You can ask us to transmit that information to you or directly to a third party organisation.
The above right exists only in respect of personal information that:
you have provided to us previously; and
is processed by us using automated means.
While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.
Consent
To the extent that we are processing your personal information based on your consent, you have the right to withdraw your consent at any time. You can do this by using the details in the Contact section below.
You can exercise any of the above rights by contacting us using any of the methods in the Contact Us section below.
Most of the above rights are subject to limitations and exceptions. We will provide reasons if we are unable to comply with any request for the exercise of your rights.
Complaints
If you are unhappy about our use of your personal information, you can contact us at privacy@womensbusinesscentre.com. You are also entitled to lodge a complaint with the UK Information Commissioner’s Office using any of the below contact methods:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Telephone – 0303 123 1111
Website – https://ico.org.uk/concerns/
If you live or work outside the UK or you have a complaint concerning our activities outside the UK, you may prefer to lodge a complaint with a different supervisory authority.
Changes to our Privacy Policy
This privacy policy can be changed by WES at any time. If we change our privacy policy in the future, we will advise you of material changes or updates to our privacy policy by email.
Further Information on Data Protection and Personal Privacy
If you have any enquiries or if you would like to contact us about our processing of your personal information, including to exercise your rights as outlined above, please contact us centrally by any of the methods below.
When you contact us, we will ask you to verify your identity.
Contact Us
Contact name – Carolyn Currie, Chief Executive
Email – privacy@womensbusinesscentre.com
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