Purposes of Processing
What data do we collect?
Life Cycle UK collects detailed information about individuals and organisations that sign up for our services, purchase our products or support our work. If you provide us with information about other people (e.g. emergency contact details) or organisations (e.g. to request cycle parking), it is your responsibility to let them know about us storing and processing their information in accordance with this policy and ensure they are happy for you to share their data with us. Life Cycle UK relies on users to say if the information is incorrect or out of date and if any alterations need to be made.
What is personal data?
Some information we collect about you is personal data. As used in this Policy, “personal data” is as defined in the UK General Data Protection Regulation and any successor or related data protection and privacy legislation (the “UK GDPR”). Personal data includes any information which, either alone or in combination with other information we hold about you, identifies you as an individual. This includes your name, postal address, email address and telephone number.
Why do we need your personal data?
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to our Site and our services - or for our volunteer, employee or freelance worker recruitment process. If you register your details on our website, over the phone or in person, you will be asked to provide this information to us. Some of our services require you to provide information in this way in order for us to deliver them.
Once you have provided us with your data, it will be processed in line with the legal basis outlined in this Policy. If you have any questions about the use of your data, please contact the Life Cycle team. We will always do our best to accommodate your requests in line with the UK GDPR.
Collecting Your Personal Data
We collect personal data in various different ways as set out below:
Information You Give Us
This includes personal data:
- You provide when you register to use our Site, our services or speak to a Life Cycle UK member of staff, volunteer, associate or partner. This information includes your name, email address and telephone number. In some cases you will be asked to provide your postal address and possibly provide demographic information (such as your gender or title);
- That may be contained in a video, photograph, comment, news article, or other content or submission you send via email or social media, or that a Life Cycle UK member of staff carries out on your behalf (with permission);
- That may be contained in a video, photograph or other media, taken by a Life Cycle UK member of staff, for example on one of our rides or at a Life Cycle UK event (this will only ever be taken and shared with your consent);
- You provide when signing up to an event or training, such as your name and contact details;
- You provide when you make an enquiry on our Site, over the phone, or directly with a Life Cycle UK member of staff;
- You provide when you sign up to our newsletter or other mailing lists through our Site; and
- You provide when you correspond with us by phone, email or otherwise.
We may also give you the option to opt-in to specific Mailing Lists or other general communications from Life Cycle UK. You can unsubscribe or update your communication preferences at any time through our communications preferences page or by clicking the link at the bottom of an email from us.
Information from Social Networking Sites
Our Site includes interfaces that allow you to connect with social networking sites (each an “SNS”). We post content on SNS such as Twitter, YouTube, Instagram and Facebook and advise you to check their privacy policies. If you connect to an SNS through our Site or other services, we will be able to access, use and store the information that you have agreed the SNS could provide to us based on your settings on that SNS. We will access, use and store that information in accordance with this Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable SNS.
We use programs such as Buffer and Hootsuite to monitor our SNS activity. If you interact with us on one of the SNS’s listed above, your public social media account information (such as your name, and the things you ‘like’) will be logged by these programs. They allow us to monitor individuals interacting with us and we use this information to improve our services.
Information we get from others
Using Your Personal Data
We may use your personal data as follows:
- To operate, maintain, and improve our Site, products, and services;
- To respond to your comments and questions and to provide customer service;
- To provide users with training, advice and support, including news, information and opportunities;
- To send you information including technical notices, updates, security alerts, and support and administrative messages;
- With your consent, to send you promotional emails about upcoming activities and other news, including information about products and services offered by us and our partners. You may opt-out of receiving such information at any time - such emails tell you how to “opt-out”;
- To send you administrative information regarding rides or training courses you have signed up to, and other correspondence regarding our business dealings with you;
- With your consent, to link you with other organisations (such as City & Guilds, Weston College and Wheels 2 Work) if this is beneficial;
- To link or combine user information with other personal data;
- As we believe necessary or appropriate to comply with applicable laws, lawful requests and legal processes, including to respond to requests from public and government authorities, to enforce our Policy, and to protect our rights, privacy, safety or property, and/or that of yours or others;
- To enhance and improve the services we provide;
- To analyse who accesses our services and any trends which might occur, for monitoring and future planning purposes;
- To analyse our impact and how well we are reaching our aims;
- As described in the “Sharing of your Personal Data” section below.
Sharing Your Personal Data
We may share your personal data as follows:
- With our third-party service providers, who provide services such as payment processing, information technology and training accreditation. These include Microsoft (who provide our email and office systems, supported by Cannard Computing Ltd), Circle interactive, Survey Monkey, Quickbooks. They are only permitted to use your personal data to the extent necessary to enable them to provide their services to us and are required to follow our express instructions and to comply with appropriate security measures to protect your personal data;
- If and when we sell or transfer all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding;
- As we believe necessary or appropriate to comply with applicable laws; to comply with lawful requests and legal processes, including to respond to requests from public and government authorities to meet national security or law enforcement requirements; to enforce our Policy; and to protect our rights, privacy, safety or property, and/or that of yours or others;
- When we are required to share your data with third parties on the basis that we are jointly undertaking or being commissioned to fulfil a contract with them; and
- With other third parties, where you have provided your consent for us to do so (unless we rely on a legal basis for sharing data under the GDPR other than consent, as outlined elsewhere in this policy).
Here are some examples of third parties that Life Cycle UK might share your data with (note: these may change as contracts, funding and partnerships change):
If you attend an event, course or training session we will share your personal details with the instructor delivering the activity, including (if relevant) details of additional needs and/or emergency contact information.
If you are attending an accredited course, we will share your personal data with the relevant accrediting body. This could include City & Guilds, 1st4Sport and/or The Bikeability Trust.
If you receive a free or discounted service, we may share limited personal details with the organisation funding or subsidising the activity or product to prove your eligibility and/or attendance. This could include Wheels to Work, Bristol City Council, Derby City Council, Weston College or Charitable Funders.
We may share limited personal data (for example DBS number, phone number, address, details of any additional needs) with our delivery partners for safeguarding reasons. Our delivery partners include schools, external training organisations, volunteers, taxi companies, delivery companies or couriers.
Financial providers or regulators
If you work for us, claim volunteer expenses or make a Gift Aid or regular donation we may share your personal data with our bank, your pension provider and/or HMRC. We may also need to share your personal data with authorised external individuals as part of an independent evaluation or audit required for legal purposes.
When we use the term “anonymous data,” we are referring to data and information that does not permit you to be identified or identifiable, either alone or when combined with any other information available to a third party.
We may create anonymous data from the personal data we receive about you and other individuals whose personal data we collect. Anonymous data might include monitoring and evaluation data (including diversity and equality forms), analytics information and information collected by us using cookies. We make personal data into anonymous data by excluding information (such as your name) that makes data personally identifiable to you.
Our Site and services may contain links to third-party websites and features. This Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their websites, features or policies. We recommend you read their privacy policies before submitting any data to them.
Interacting with Life Cycle UK online
You may share personal data with us when you submit content to our social media pages, such as a comment on a post, photo or video. Please note that any information you post or disclose on our social media pages in this way will become public information, and will be available to others who access these platforms and to the general public. We urge you to be very careful when deciding to disclose your personal data, or any other information, on social media in this way. Such personal data and other information will not be private or confidential once it is published on our social media pages.
If you provide feedback to us, about our Site or services, we may use and disclose such feedback, without your personal data attached, on our Site, in our fundraising activities, to our funders or in advertisements.
Location and accessibility of data
Information in Life Cycle UK’s files and database is stored on secure servers in the United Kingdom and/or European Union and we have implemented the appropriate measures to protect it from improper access, destruction, tampering and loss.
Data held by Life Cycle UK is accessible to all our staff members and our IT support contractors so that we can provide thorough and personalised support. Access to sensitive personal information is limited to those employees who need it to perform their roles. Where data is shared with third-party service providers (e.g. Survey Monkey), we only use reputable providers who comply with the UK GDPR.
Life Cycle UK has an internal data protection policy that requires staff and contractors to follow all applicable laws and regulations, including to not share information outside of Life Cycle UK unless required to do so by law.
We seek to use reasonable organisational, technical and administrative measures to protect personal data within our organisation, in compliance with applicable laws and regulations. Our IT support contractor uses an Information Security Management System (ISMS) that is ISO 27001 accredited, and as such implements and maintains technical and organisational measures to ensure ongoing confidentiality, integrity, availability and resilience of our systems.
We will only retain your personal data for a maximum of 36 months after your last interaction with our Site, access to our services or another contact with Life Cycle UK unless a longer retention period is required or permitted by law (for example for regulatory purposes). However, it is common for service or funding contracts to require data relating to their delivery to be retained by the provider for a number of years after the contract has been completed. Therefore, Life Cycle UK may retain some information for archival purposes and historical analysis for more than 36 months in order to comply with such requirements.
Our Policy on Children
Whilst much of our work is with adults, Life Cycle UK provides cycle training to children and our Youth Project caters for children and young people. We collect some personal data on the young people we work with, and this data is either submitted by a consenting parent or carer, or (at the Youth Project) collected by our youth workers in order to provide a safe and effective service to the children we work with.
Our Youth Project records details of a child’s progress during their time with us so we can evaluate the difference we are making to their life. This information is only shared with funders and is always completely anonymised first. All data is held and destroyed securely and is only accessible to the relevant members of Life Cycle UK staff.
We do not market our services to, or directly communicate with, anyone under 18.
Special Category Personal Data
Special category personal data includes information related to racial or ethnic origin, political opinions, religion or other beliefs and health. Special category personal data, as well as information about criminal convictions and offences, is more heavily protected by data-protection laws. Providing special category or criminal conviction personal data is never a requirement to use our Site or services. If you choose to provide us with this information, you must make sure you are happy for us to use it in accordance with this Policy. If you do not want us to use this type of personal data, you must not submit such information to our Site or services.
In some instances, we may request special category personal data from you, which is not mandatory to provide. This is to monitor our Site and services and ensure they are accessible to all demographics and we do this on the basis that it is in the public interest to do so to monitor equality of opportunity. Volunteers, freelancers and staff that apply to work with children or vulnerable adults will need to submit special category personal data for vetting and safeguarding purposes. This is to ensure that we can comply with legal obligations in relation to safeguarding.
If you are purchasing a product or service from us over the phone with a credit or debit card, a member of Life Cycle staff will take your card details and enter it into a password protected Sage Pay portal. We do not write down or store these details on our systems or on paper. When you purchase a product or service via our website, we do not retain any records of your card details.
Legal basis for processing
Data protection laws mean that each use we make of personal information must have a “legal basis”. The legal bases are set out in the UK GDPR. Life Cycle UK processes data under the following bases:
Consent is where we ask you if we can use your information in a certain way, and you agree to this (for example when we send you marketing e-mails). Where we use your information for a purpose based on consent, you have the right to withdraw consent for any future use of your information for this purpose at any time.
We have a basis to use your personal information where we need to do so to comply with one of our legal or regulatory obligations. For example, in some cases we may need to share your information with our various regulators such as the Charity Commission, HMRC or to use the information we collect about you for our financial records.
Performance of a contract / take steps at your request to prepare for entry into a contract
We have a basis to use your personal information where we are entering into a contract with you or performing our obligations under that contract. Examples of this would be if you are buying something from us (for instance a refurbished bicycle, a Dr Bike session or some bike mechanics training), applying to work/volunteer with us, or signing up to attend cycle training or one of our group rides.
We have a basis to use your personal information where it is necessary for us to protect your or someone else's vital interests. For instance, if there were to be an emergency impacting individuals at one of our events, or a safeguarding issue that required us to contact people unexpectedly or share their information with emergency services.
We have a basis to use your personal information if it is reasonably necessary for us (or others) to do so and in our/their “legitimate interests” (provided that what the information is used for is fair and does not unduly impact your rights). We consider our legitimate interests to include all of the day-to-day activities Life Cycle UK carries out with personal information. Some examples not mentioned under the other bases above, where we are relying on legitimate interests include:
• use of personal information when we are monitoring the use of our website for technical purposes;
• use of personal information to administer, review and keep an internal record of the people we work with, including supporters, volunteers and researchers;
• analysis and profiling of our supporters using personal information we already hold; and
• sharing of personal information between relevant staff members, volunteers and freelance workers within Life Cycle UK and between Life Cycle UK’s delivery partners.
We only rely on legitimate interests where we consider that any potential impact on you (positive and negative), how intrusive it is from a privacy perspective and your rights under data protection laws do not override our (or others’) interests in us using your information in this way.
When we use special category personal information (please see the “Special Category Personal Data” section above), we require an additional legal basis to do so under data protection laws, so we will either do so on the basis of your explicit consent or another route available to us at law for using this type of information (for example if you have made the information manifestly public, we need to process it for employment, social security or social protection law purposes, your vital interests, or, in some cases, if it is in the public interest for us to do so).
You have the right to object to Life Cycle UK’s processing of your data unless:
• The data has been given with your consent (in which case you can withdraw consent);
• It has been collected or processed for the purposes of fulfilling a contract with you;
• If we have collected it because we have a legal obligation to do so;
• It has been collected in order to protect life or health.
You should note that we will not always be required to stop processing your personal data if you object. If we are not, we will explain why to you when we respond to your request.
You may contact us at any time to opt-out of direct marketing communications.
You may access the information we hold about you at any time by contacting us directly using the contact details at the bottom of this page.
You can contact us to update or correct any inaccuracies in your personal data. We periodically remind individuals whose data we hold to review and correct the information we hold on them, and it is their responsibility to maintain the accuracy of information we hold about them or tell us about any issues. We are not liable for any damages caused by the information you get from our Site or any connections made to it.
Your personal data is portable, and you have the right and flexibility to receive an electronic copy of the personal data that you have provided to us and to move that personal data to another service provider if you wish, provided that the personal data is processed for the purposes of entering into or fulfilling a contract with you, or on the basis of your consent. To do this please contact us, stating what information you would like to transport and who to.
Erase and forget
You have the right to request we erase data you no longer want us to hold in certain circumstances. We will not always be obliged to comply and erasure may mean you can no longer access our services, and it may impact your use of our Site. In particular, we may need to retain certain information for legal, recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion. In most cases, we will be able to anonymise your record, remove any extraneous personal data, and keep a record that an anonymous individual has undertaken certain activities or transactions with Life Cycle UK.
There are some exemptions to the rights above, which means that we do not always have to comply with them, or we may be able to exclude certain information from the response to the request. For example, we can withhold information requested as part of an access request if releasing the information would prejudice an ongoing criminal investigation. If we are relying on an exemption, we will make this clear when we respond to your request.
How to exercise your data protection rights
If you wish to exercise any of the rights detailed above, please contact us using the details in the “Contact us” section below. In your request, please make clear the following:
• What personal data is concerned;
• Which of the above rights you would like to enforce.
We may need to verify your identity before implementing your request and will try to comply with your request within one month of receiving your request. If you wish to enforce any of your rights, please contact us.
What are cookies?
Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.
Cookies we use
We use two broad categories of cookies: first-party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Site; and third-party cookies, which are served by service providers on our Site, and can be used by such service providers to recognize your computer or mobile device when it visits other websites. Some of these cookies are essential to ensure our Site works as expected. Others are non-essential cookies that anonymously track visitors to enhance your experience of our Site. You are able to disable these cookies (instructions below), but some features of our Site may then be unavailable.
Our Site uses the following types of cookies for the purposes set out below:
These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to carry out tasks (such as booking onto a group ride), and help the content of the pages you request load quickly. Without these cookies, you will not be able to use some features of our Site.
These cookies allow our Site to remember choices you make when you use our Site, for example remembering your language preferences or login details. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
Analytics and Performance Cookies
These cookies are used to collect information about traffic to our Site and how users interact with our Site. This information does not identify any individual visitor, it is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site and services more efficiently, to gather broad demographic information and to monitor the level of activity on our Site.
We use Google Analytics to monitor this website activity and improve our services. You can find out more about how Google protects your data here. You also have the right to object to Google Analytics processing your data and can prevent this by downloading this browser plugin.
Social Media Cookies
These cookies are used when you share information using a social media sharing button or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Instagram. The social network will record that you have done this.
You can remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to automatically accept cookies until you change your settings.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.co.uk
If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognize your computer or mobile device and you may need to re-input your details every time you visit our Site.
We may use pixel tags (which are also known as web beacons and clear GIFs) to track mail openings of users who are signed up to receive information via email. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. The information we collect using pixel tags is not linked to our users’ personal data.
We are committed to resolving any complaints about our collection or use of your personal data. If you would like to make a complaint regarding this Policy or our practices in relation to your personal data, please contact us. We will respond to your complaint within 30 days and in accordance with our Complaints Policy. We hope to resolve any complaint brought to our attention, however, if you feel that your complaint (about our use of your data) has not been adequately resolved, you have the right to contact the Information Commissioner’s Office.
Address: The Create Centre, Smeaton Road, Bristol, BS1 6XN
Telephone: 0117 353 4580