info@nationalsilvergloves.org
Silver Gloves of America Website Privacy and Data Protection Policy (GDPR)
1.1 Commitment to Privacy
Silver Gloves of America is committed to safeguarding the privacy of our website visitors.
1.2 Scope of Policy
This policy applies where we are acting as a data controller with respect to the personal data of our website visitors or stakeholders and clients; in other words, where we determine the purposes and means of the processing of that personal data.
1.3 Privacy Controls
Our policy incorporates privacy controls which affect how we will process your personal data.
1.4 Terminology
In this policy, “we”, “us” and “our” refer to Silver Gloves of America.
How we use your personal data
2.1 General Categories of Personal Data
Silver Gloves of America identifies general categories of personal data that we may process; in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; the purposes for which we may process personal data; and the legal bases of the processing.
2.2 Usage Data
We may process data in various ways, such as your use of our website (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use.
The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website services.
2.3 Profile Data
We may process your information included in your personal profile (“profile data”). The profile data may include your name, address, telephone number, email address. The profile data may be processed for the purposes of enabling and communicating with you.
2.4 Enquiry Data
We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
2.5 Customer Relationship Data
We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
2.6 Notification Data
We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”) or by other communication methods. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.7 Correspondence Data
We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.8 Legal Claims
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.9 Personal Data of Others
Please do not supply any other person’s personal data to us, unless we prompt you to do so.
Providing your personal data to others
3.1 Disclosure to Third Parties
We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
3.2 Legal Obligations and Claims
In addition to the specific disclosures of personal data set out, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Retaining and Deleting Personal Data
4.1 Retention Policies
Silver Gloves of America’s retention policies and procedures are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2 Data Retention Period
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose.
4.3 Retention Duration
We will retain your personal data for a minimum period of 2 years and for a maximum period of 6 years.
4.4 Exceptions
Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Your Rights
5.1 Overview
The rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
5.2 Principal Rights
Your principal rights under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
5.3 Right to Access
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned, and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply you with a copy of your personal data.
5.4 Right to Rectification
You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
5.5 Right to Erasure
In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions to the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise, or defence of legal claims.
5.6 Right to Restrict Processing
In some circumstances, you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise, or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise, or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
5.7 Right to Object to Processing
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defence of legal claims.
5.8 Right to Object to Direct Marketing
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
5.9 Right to Object to Research or Statistical Processing
You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
5.10 Right to Data Portability
To the extent that the legal basis for our processing of your personal data is: (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used, and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
5.11 Right to Withdraw Consent
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.
5.12 Exercising Your Rights
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this section.
Contact Information
Please contact the Silver Gloves of America Headquarters relating to Data Protection at info@nationalsilvergloves.org.