This Privacy Policy is edited by The Why Not? Trust, a charity having its registered office at Bremner House, Castle Business Park, Stirling, Scotland FK9 4TF and registered with the Scottish Charity Regulator under the number SC048633, (hereafter, the “Data Controller”).

The Data Controller offers a platform for young care leavers and their Connectors to interact, access information relevant to them and engage with our community and events, (hereafter, the “Platform”) to its users which have subscribed on the Platform and as such have a user account (hereafter, the “Users”). The Platform is available at the following url address www.whynothub.org.

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

In this regard, the Data Controller collects and processes User’s personal data in accordance with the Privacy and Cookie policy.

The Data Controller is particularly aware and sensitive with regards to the respect of its Users privacy and personal data protection. The Data Controller commits to ensure the compliance of the processing it carries out as Data Controller in accordance with the Data Protection Law.

Data Protection Law is the Data Protection Act 2018 (UK) and the EU Regulation n°2016/679 regarding data protection dated April 27, 2016 named General Data Protection Regulation or “GDPR”.

The Data Controller has put in place an appropriate privacy and cookie policy to be fully transparent on how the personal data of Users are processed within the use of the Platform and services provided.

This privacy policy is intended for the Users of the Platform of the Data Controller.

The Data Controller has appointed a Data Protection Officer (hereinafter “DPO”) you may contact at the following address: [email protected]

Date of last update: 26/08/2022.

 

1. COLLECTED PERSONAL DATA

 

1.1 When subscribing on the Platform

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

Mandatory data

• First name ;

• Last name ;
• Email address ;
• Date of Birth ;
• Gender ;
• Category ;
• Location

Optional data:

• Hobbies, interests,

 

The User is informed that it is not possible to access the Platform without providing the mandatory data strictly necessary to create an account and authenticate the User.

 

1.2 During the use of the Platform

The User may validly publish, at its own initiative, any content on the Platform which shall be kept by the Company:

 

• Posts ;
• Comments ;
• Photos ;
• Videos

 

The User is aware that when using the Platform, the User 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, the User agrees to their processing by the Platform in the conditions set forth in this Privacy Policy.

    

2. THE PURPOSE OF THE DATA PROCESSING

The Data Controller and its subcontractors process personal data that are freely transferred by the User when accessing the services proposed by the Platform for the following purposes:

 

Purpose	Legal basis
Creation and management of a user account;	Consent
Providing the User with all functionalities of the Platform, meaning: Sending invitations for events organized by Data Controller, if the User has accepted to receive such invitations; Invite the User to events organized by the Platform
Management of data subjects rights according to the Personal Data Legislation. Storage of User personal data;
Making statistics in order: to improve the quality of the services proposed by the Platform; improve the usage functionalities of the Platform;
Making statistics regarding the effective use of the Platform;
Making statistics regarding the different levels of activity on the Platform.

 

 

 

3.  DATA RETENTION PERIOD

The Data Controller informs the User that the personal data related to the User Account is retained only during the length of the User’s subscription on the Platform.

Following the termination of said subscription, the data collected upon the subscription as well as the content published by the User on the Platform shall be deleted after a period of 6 months.

 

4. DATA TRANSFERS

The Users’ data are stored in the European Economic Area (EEA) by the Data Controller and its trusted service providers. However, depending on the processing, the Users’ data may also be transferred in a country outside the EEA, to our trusted service providers.

When transferring data outside the EEA, the Data Controller ensures that the data are transferred in a secured manner and with respect to the Data Protection Law. When the country where the data are transferred does not have a protection comparable to that of the EU, the Data Controller uses “appropriate or suitable safeguards”.

When the service providers to whom personal data are transferred, are located in the United States, these transfers are governed by the standard data protection clauses adopted by the Commission.

Users can access information on such safeguards by contacting the DPO at the following address: The Why Not? Trust, Bremner House, Castle Business Park, Stirling FK9 4TF or [email protected].

 

5.   COMMITMENT OF THE DATA CONTROLLER

The Data Controller commits to process User’s personal data in compliance the Data Protection Law and undertake to, notably, respect the following principles:

• Process User’s personal data lawfully, fairly, and in a transparent manner;
• Only collect and process the Users’ 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 personal User’s 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 the Users’ data to the persons duly authorized to this effect;
• Guarantee to the Users their rights under the Data Protection Law in relation to the processing of their data and make the best efforts to satisfy any request, where this is possible.

 

6. EXERCISE OF THE USERS’ RIGHTS

The User is duly informed that it disposes at any time, depending on the legal basis of the processing, a right to access, to rectification, to erasure, to restriction of processing, to data portability, and to object.

When processing is based on User’s consent, the right to withdraw consent at any time, without affecting the lawfulness of the processing based on consent before its withdrawal.

The User can exercise its rights by sending an email to the following address [email protected] or by mail at the following address The Why Not? Trust, Bremner House, Castle Business Park, Stirling FK9 4TF provided that the User justifies his/her identity.

In addition, in the event the User considers that its rights have not been respected, the User of which the personal data is collected 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.

 

7. COOKIES

The Data Controller informs the User that Hivebrite, as well as its subcontractors, uses a tracking technology on its terminal such as cookies whenever the User navigates on the Platform subject to the conditions described in the Data Controller Cookie Policy at www.whynothub.org.  

 

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

 

Only authorised persons working for the Data Controller and, in some cases, its subsidiaries, can access your personal data. The Data Controller makes its best effort to ensure that these groups of people remain as small as possible and maintain the confidentiality and security of User’s personal data.

 

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

    

The Data Controller only provides service providers with the information they need to perform the service and ask them not to use your personal data for any other purpose. The Data Controller does his 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.

 

The Data Controller 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 Why Not? Trust, 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 the User, 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