This is the Privacy Policy for the platform offered by Jamie’s Farm, a Limited Company with Charitable Status having its registered office at Hillhouse Farm, Ditteridge, Box, Wiltshire SN13 8QA registered with Companies House under the number 06820259, and the Charity Commission under the number 1129544  (hereafter, "we", "our" or "us" or "Company").

We offer a platform; Cultivating Change (hereafter, the “Platform”) to users which have subscribed on the Platform and as such have a user account (hereafter, “you” or "your"). The Platform is available at the following URL address [https://cultivating-change.hivebrite.com/]

We use a solution called “Hivebrite”, which enables the import and export of user lists and data, the management of content and events, the organization of emailing campaigns and opportunity research and sharing as well as the management of funds and contributions of any kind.

In this regard, we collect and process your personal data in accordance with this Privacy Policy and the Cookie Policy [insert link to cookie policy].

We are particularly aware and sensitive with regards to the respect of your privacy and personal data protection. We commit to ensure the compliance of the processing we carry out as data controller is in accordance with the Data Protection Law.

Data Protection Law is the EU General Data Protection Regulation n°2016/679 ("EU GDPR") and the UK implementation of the EU GDPR ("UK GDPR") (each Regulation is referred to as  "Data Protection Law" unless otherwise stated)

The terms "controller", "processor", "data subject", "personal data", "process", "processes", and "processing" used in this Privacy Policy have the meanings given to them under Data Protection Law.

 

We have put in place this privacy policy and the cookie policy to be fully transparent on who we are, how and why we collect, store, use and share personal information, individual rights in relation to personal data and how to contact us and supervisory authorities in the event of a complaint.

This Privacy Policy is intended only for you as a user of the Platform.

We have appointed a Data Protection Officer (hereinafter “DPO”) you may contact at the following address: Jake Curtis, Jamie’s Farm, Hillhouse Farm, Ditteridge, Box, Wiltshire SN13 8QA, [email protected]

Date of last update: 21/02/2024

 

  1. 1. COLLECTED PERSONAL DATA

 

1.1 When subscribing to the Platform

When subscribing to the Platform, you are informed that the following personal data is collected for the purpose of creating a user account:

Mandatory data

  • First name;
  • Last name;
  • Email address; and
  • Role (e.g. teacher).

 

Some optional data is also collected, if you choose to provide it. This includes email address, phone numbers, postal address, job experience (function and industries), education (field of study and school name), honorary title, gender, maiden name, birth date, citizenships, location, CV, role, and social media links.

You are informed that it is not possible to access the Platform without providing the mandatory data strictly necessary to create an account and authenticate you. You may delete the optional data at any time.

 

1.2 During the use of the Platform

The Platform provides you with the ability to join groups or post in forums or groups. You may publish, at your own initiative, any content on the Platform, which shall be processed by us:

  • Public posts on the home newsfeed or within groups
  • Posts within private pages that can be made available for specific groups and/or memberships
  • Details concerning events

 

When using the Platform, you may decide to provide sensitive data within the meaning of Data Protection Law, for example, data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, concerning sexual orientation, etc. By providing such sensitive data, you consent to the processing by the Platform in the conditions set forth in this Privacy Policy.

    

  1. 2. THE PURPOSE OF THE DATA PROCESSING

We process and our subcontractors process personal data that is transferred by you when accessing the services on the Platform for the following purposes:

  • Creation and management of a user account
  • Creation of user profiles
  • Providing you with all functionalities of the Platform, meaning:
    • Sending invitations for events organized by us or other users, if you have accepted to receive such invitations
    • Sending offers from us or our partners if you have accepted to receive such offers
    • Invite you to events organized by the Platform
    • Invite you to groups that may be of interest
  • Management of data subjects rights according to Data Protection Law, including storage of your personal data
  • Management of prospection operations:
    • Sending email prospect campaigns in the Jamie’s Farm name and/or its commercial partners
    • Sending newsletters from Jamie’s Farm and/or its commercial partners
    • In each case, where you have consented to receive such communications. The option to withdraw consent at any time will be included in all communications.
  • Making statistics in order to improve the quality of the services proposed by the Platform and to improve the usage functionalities of the Platform;
  • Making statistics regarding the effective use of the Platform and the different levels of activity on the Platform;
  • Enable the synchronization of your LinkedIn profile

We rely on different lawful bases to process your personal data, being:

  • Article 6(1)(b) of the Data Protection Laws to the extent such processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into any such contract. Examples of this might include signing up to the Platform and your use of the Platform.
  • Article 6(1)(f) of the Data Protection Laws to the extent such processing is necessary for the purposes of the legitimate interests pursued to the extent that the processing is not overridden by your interests or fundamental rights or freedoms that require the protection of personal data. Examples of this might include any marketing and processing for the purposes of compliance with internal policies and procedures.
  • Article 6(1)(c) of the Data Protection Laws to the extent processing is necessary for compliance with a legal obligation to which the Data Controller is subject. Examples of this might include obligations relating to anti-money laundering, fraud prevention, sanctions, and politically exposed persons.
  • Article 4(11) and Article 7 of the Data Protection Laws where your consent to the relevant processing activity has been obtained. This will not be generally relied upon if another processing ground is relied on instead.

It is not envisaged that any personal data will undergo any automated decision making.

  1. 3. DATA RETENTION PERIOD

We only retain the personal data related to your account for the length of your subscription on the Platform.

Following the termination your subscription, the data collected from the subscription as well as the content published by you on the Platform shall be deleted after a period of 90 days, save for any retention of data for a period necessary for compliance with a legal obligation to which we are subject to.

 

  1. 4. DATA TRANSFERS

Your data is stored in the European Economic Area (EEA) by us, our subsidiaries and our trusted service providers. However, depending on the processing, your data may also be transferred in a country outside the EEA, to our trusted service providers.

When transferring data outside the EEA, we ensure that the data is transferred in a secured manner and with respect to Data Protection Laws. When the country where the data is transferred does not have a protection comparable to that of the EU, we use “appropriate or suitable safeguards”.

You can contact the DPO at the following address: Jake Curtis, Jamie’s Farm, Hillhouse Farm, Ditteridge, Box, Wiltshire SN13 8QA

 

  1. 5.   COMMITMENT OF THE DATA CONTROLLER

We commit to process your personal data in compliance with Data Protection Law and undertake to, notably, respect the following principles:

  • Process your personal data lawfully, fairly, and in a transparent manner;
  • Only collect and process your data for the strict purpose as described under Article 2 of the present privacy policy;
  • Ensure that the personal data processed are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  • Do the best efforts to ensure that the personal data processed are accurate and, if necessary, kept up to date and take all reasonable steps to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
  • Keep your personal data for no longer than is necessary for the purposes for which they are processed;
  • Put in place all necessary technical and organizational appropriate measures in order to ensure the security, confidentiality, integrity, availability and the resilience of the process systems and services;
  • Limit the access to your data to the persons duly authorized to this effect;
  • Guarantee to you, your rights under Data Protection Law in relation to the processing of your data and make the best efforts to satisfy any request, where this is possible.

 

  1. 6. EXERCISE OF THE USERS’ RIGHTS

The Data Protection Law provides you (as the data subject) with a number of rights in relation to the processing of your personal data. These include:

  • the right to know what personal data we process and a right of access to such personal data;
  • the right to request any incomplete or inaccurate personal data to be corrected;
  • the right to object to our processing of your personal data;
  • the right to require us to delete your personal data in some limited circumstances;
  • the right to object to our processing of some or all of your personal data on grounds relating to your particular situation which are based on legitimate interests, at any time (and require such personal data to be deleted). If you object, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for such processing which override your interests, rights and freedoms or where it is necessary for the establishment, exercise or defence of legal claims;
  • a "data portability" right to require us to transfer your personal data to you or to a new service provider in a structured, commonly used and machine-readable format;
  • the right to withdraw consent at anytime when processing is based on your consent.

You can exercise your rights by sending an email to the following address [email protected] or by mail at the following address; Jamie’s Farm, Hillhouse Farm, Ditteridge, Box, Wiltshire SN13 8QA, provided that you justify your identity.

In addition, in the event you consider that your rights have not been respected, you can lodge a complaint before the competent supervisory authority. For any additional information, you can review your rights on the websites of the competent authorities.

The competent supervisory authorities are listed on the following website:

http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

In the UK, the competent supervisory authority is the Information Commissioner's Office:

https://ico.org.uk/

  1. 7. COOKIES

We inform you that Hivebrite, as well as our subcontractors, use a tracking technology on their terminal such as cookies whenever you navigate on the Platform subject to the conditions described in our Cookie Policy. 

 

  1. 8. RECIPIENT AND PERSONS AUTHORIZED TO ACCESS THE USERS’ DATA

 

Only authorized persons working for us can access your personal data. We make our best effort to ensure that these groups of people remain as small as possible and maintain the confidentiality and security of your personal data.

 

We also use trusted service providers to carry out a set of operations on our behalf for hosting and payment services. We also use service providers in the tech industry, editors of specific tools integrated in the Platform for technical purposes.

    

We only provide service providers with the information they need to perform the service and ask them not to use your personal data for any other purpose. We do our best to ensure that all these trusted service providers only process the personal data on our documented instructions and provide sufficient guarantees, in particular in terms of confidentiality, expert knowledge, reliability and resources, to implement technical and organizational measures which will meet the requirements of the applicable legislation, including for the security of processing.

 

We may be required to disclose or share your personal data to comply with a legal obligation, or to enforce or apply our terms of use/sale or any other conditions you have accepted; or to protect the rights, safety or property of the Company, its customers or employees.

 

List of the main service providers:

 

Service Provider

Service

You can consult the privacy policy by clicking on the following link:

KIT UNITED

 

44 rue la fayette

75009 Paris

France

HIVEBRITE solution

 

 

 https://hivebrite.com/privacy-policy

 

 

 

 

 

 

 

 

Google Cloud Platform

Gordon House, 4 Barrow St,

Dublin, Ireland

Hosting of all data and content produced / provided by you, as well as images, profile pictures and backups

https://cloud.google.com/security/privacy/

 

 

Amazon AWS

38 avenue John F. Kennedy,

L-1855, Luxembourg

 

https://aws.amazon.com/compliance/gdpr-center/

Sentry

132 Hawthorne Street San Francisco,

CA 94107

USA

 

Production and storage of error logs enabling our developers

to correct the code

https://sentry.io/privacy/

Sendgrid

375 Beale Street, Suite 300,

San Francisco, CA 94105

USA

Sending of emails from the Platform

https://api.sendgrid.com/privacy.html

Hivebrite, Inc.

16 Nassau St,

New York, NY 10038,

USA

Customer support for the Platform

 https://hivebrite.com/privacy-policy