JOINT CONTROLLER STATEMENT
Data protection compliance is a key part of how we as babyballet operate our business.
This policy explains the nature of the relationship between babyballet Franchising Limited (babyballet) and the UK franchisee network in relation to the way that we handle your personal information. For the purposes of Article 26 of the General Data Protection Regulation (“GDPR”), it sets out the legal relationship between us in relation to your personal information and our respective responsibilities to ensure that we comply with the law.
In this policy, a reference to “we”, “our” or “us” is a reference to babyballet and the UK franchisee network.
If you have any questions about this policy, please contact babyballet at firstname.lastname@example.org
Joint Controller Relationship
babyballet is a franchised business operated by independent franchisees.
It is important for the operation of our business that your personal information is transferred between babyballet and the franchisee network (and vice versa) to enable us to provide our services to you, for example, processing your orders that are submitted online. We also share your data so that we can conduct our marketing activities. This is usually limited to name, contact details and images (Shared Personal Data).
We are “joint controllers” of this Shared Personal Data. This means that we may jointly determine the purposes and means of processing your personal data. It also means that babyballet will determine the purpose for which babyballet uses your personal data and a franchisee which has also collected your personal data will determine the purpose for which it uses your personal data.
This policy sets out the arrangements that have been agreed between babyballet and the UK franchisee network as joint controllers of the Shared Personal Data, including who will be responsible for providing you with information about how and why we use your information and who will be responsible for dealing with a request from you.
What Do We Do With Your Personal Information?
It is important to us that we are transparent in the ways that we use your personal information.
If a franchisee collects your personal information at a class for example that franchisee is individually responsible for informing you about how it will process your personal information. This processing is likely to include the use of your personal data for providing the services to you. The franchisee may also elect to retain your personal data for its direct marketing purposes which may involve contacting you from time to time via email. For more information on the privacy practices of any of our franchisees, please contact the relevant franchisee.
Data collected by babyballet and / or any of the UK franchisees may be stored on babyballet’s centralised database. It may also be stored on a franchisee’s systems where you have had direct engagement with that franchisee.
Who Is Responsible For Dealing With A Request From You?
You have a right to request access to or rectification of your personal data which we hold about you. You also have a right to erase your personal data, to restrict the processing of your personal data and the right to receive your personal data that you have provided to us, the right to object to our processing of your personal data and a right to request that we transmit your personal data to another data controller.
You have a right to submit any such request to either babyballet or a franchisee directly. The entity that you submit the request to shall be responsible for dealing with the request and responding to you.
If you submit a request to one of our franchisees or babyballet directly, the relevant controller will respond to you. However, to ensure your request is dealt with in full, you may wish to consider submitting your request to both the franchisee and babyballet.
We are committed to protecting and respecting your privacy.
Grandad Jack, the King of the babyballet® Castle in the Sky kindly asks you to read the following!
We are a limited company registered in England and Wales under company number 06793999 and our registered address is at Kemp House 160 City Road, London EC1V 2NX. The best way to contact us is by email at email@example.com. Alternatively, you can use our ‘Contact Us’ form on our Website. For the purpose of the Data Protection Act 1998 (the Act), we are the “data controller” and we have notified the Information Commissioner’s Office that we process personal data (under Z3659959).
Information we may collect from you
Grandad Jack knows how important people’s personal data is and therefore make sure that we all treat any personal data we collect as confidential. There are times, though, that we need to share your data with relevant selected third parties and by providing your personal data, you are agreeing to us sharing this.
We may collect, process and store information about you that is provided to us by you or collected from your visits to our Website. Such information may have been collected, for example, in relation to providing you with newsletters and email alerts. We try to keep the information secure and up to date, and we have a policy of deleting your information if it is no longer needed.
How do we use and share your information?
We use your information:
- to carry out any services you have requested from us;
- to send you newsletters;
- to ensure that content from our Website is presented in the most effective manner for you and for your internet browser;
- to allow you to use any interactive features of our service if required;
- to notify you about changes to our services;
- to prevent, detect, and investigate potentially prohibited or illegal activities and enforce our Terms of Website Use;
- to provide you with other marketing information, products or services that you request from us or which we feel may interest you.
We will not sell your name, address, e-mail address, or personal information to any third party without your permission. We will share your information with our carefully selected service providers to enable us to carry out our services, we may also share your information to enable us to comply with any applicable laws or lawful government and/or regulatory requests. In the event that we sell or buy any business or assets we may disclose and/or transfer your personal data to the prospective buyer or seller.
Sometimes we may ask for your permission to share your information with business partners, sponsors, advertisers and promoters (for example, if you enter a prize draw, competition or promotion, we may (if we tell you) share your information with any third party involved in that prize draw).
If you order an item from us and it is sent to you by courier, the label will display your name, address and telephone number to facilitate a successful delivery attempt in accordance with courier practice.
You have the right to opt out of marketing contact at any time. Please let us know by sending an email to us at firstname.lastname@example.org, or by any of the methods detailed on our ‘Contact Us’ page.
Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites please note that these websites have their own privacy policies and that we do not accept responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
The Data Protection Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 as a contribution to our costs in providing you with details of the information we hold about you.
How we protect your information
Grandad Jack makes sure that all personal data is well looked after and we always take reasonable steps to ensure that all data is treated securely and in accordance with all relevant laws. The information you provide to us will usually be stored and processed on servers based within the United Kingdom but you agree that we may store the data on carefully selected portable devices, in paper files, and to transfer data abroad. It may be processed by staff operating outside the European Economic Area (“EEA”) who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We do our best to ensure that your personal data is kept securely.
Once we have received your personal data we will use all our powers and security features to try and prevent any unauthorised access but, unfortunately, the internet is a big scary place where not everyone is nice to each other. Therefore, we have to say that whilst we will do our utmost best to protect your data, we cannot guarantee the security of any transmitted data to our site and therefore any transmission is at your own risk. Sorry.
Our Website uses “cookies”, which are small text files that are stored on your computer. Grandad Jack told me all about cookies. I told him that my favourites were white chocolate chip and ones with pink smarties. Grandad Jack told me the ones that he was talking about couldn’t be eaten! I asked him what good was that? He said that cookie files can be stored on the hard drives of computers and that they provide information about general internet usage. I don’t think they sound half as nice as my cookies. Anyway, he said that we use computer cookies to help us to improve our website and deliver a better and more personalised service.
Grandad Jack says that these cookies allow us to distinguish you from other users of our Website and help us improve our Website. The information saved supports the functionality of the Website. During some processes, data is temporarily stored as you move from step to step. This improves your experience of the Website, and data is only stored for as long as is necessary for you to complete the process. All other cookies will expire after 60 minutes.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our Website. Without these cookies, interactive services such as shopping baskets cannot be provided.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
Grandad Jack has added plugins to this site called LogRocket & Sentry. He says they let us record people using the site such as you and so helps us to reproduce bugs (not creepy crawlies) and fix issues faster. Essentially it shows us any server errors whilst users are performing operations so that we can track them.
Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you.
Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Grandad Jack says that you can refuse to accept cookies if you like because we are always told never to accept cookies from strangers, but if you do reject our cookies, it may mean that you are unable to access certain parts of our website. You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.
All comments, queries and requests relating to our use of your information are welcomed and should be e-mailed to us at email@example.com, or by any of the methods detailed on our ‘Contact Us’ page.
Grandad Jack, The King of the Castle
We as Babyballet Franchisees are committed to protecting and respecting your privacy.
We are a franchise business operating under licence from Babyballet Franchising Limited.
- Information we collect
Personal data from you:
- Contact details (e.g. name, address, phone number, email address) when you make enquiries, book or register your child for classes;
- Payment details such as bank account and payment card details for example for parties, shows, mechanises and nurseries;
- Your child’s data of birth;
- Photographs and video footage
Sensitive personal information:
- Information about your child’s health including any medical condition, health and sickness records
- Information about your/ your child’s race or ethnicity and religious beliefs
From third parties:
- We may receive information about you or your child from our franchisor where you make an enquiry, register or book a class through their website.
- How we use your/ your child’s personal data
We will only use your personal information when the law allows us to. Most commonly this will be:
- Where we need to perform the contract we have entered into with you e.g.:
- To register or book your child onto one of our classes
- To carry out the services you have requested and/or your child participates in e.g. parties, shows and nurseries
- To manage our relationship with you
- To manage payment e.g. when you purchase merchandise
- To process and deliver your orders
- Where we need to comply with a legal obligation e.g.:
- Health and safety legislation
- Where it is within our legitimate interests and your interests or fundamental rights do not override those interests; e.g.:
- To provide you with information about events and news
- To send you communications about changes to our terms and conditions and policies
- To protect yours or your child’s vital interests e.g.:
- In an emergency situation
- Where you have given us your explicit consent e.g.:
- Where we would like to use photos or images taken of you or your child in promotional materials.
Special categories of personal data
We will only process this category of data where you have given us your explicit consent and/or it is necessary to protect the vital interests of you or your child e.g. to ensure your child’s health and safety.
We may use this category of information where it is needed in the public interest such as for equal opportunities monitoring.
We operate as an independent franchise business of babyballet Franchising Limited. It is important for the operation of our business that some of your personal information is transferred between us and babyballet (and vice versa) to enable us to provide our services to you, for example, if you register via the babyballet website. See the Joint Controller Statement on the babyballet website for more information.
We will share your data with our authorised personnel including but not limited to teachers, chaperones and administrative staff. We may also have to share your personal data with (i) service providers who provide IT and system administration support, warehouse suppliers and distributors (ii) professional advisors including lawyers, bankers, auditors and insurers (iii) HMRC and other regulatory authorities (iv) third parties to whom we sell, transfer or merge parts of our business or our assets and/or (v) charities we support as appropriate.
We require all of these third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
- International Transfer
We do not transfer your data outside the EEA.
- Data Security
We have put in place security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breaches and will notify you and any applicable regulator where we are legally required to do so.
- Data Retention
We will only keep your personal data for as long as is necessary to fulfil the purposes for which we collected it. We may retain your data to satisfy any legal, accounting, or reporting requirements so for example we need to keep certain information about you for 6 years after you cease to be a client for tax purposes.
- Your rights
You are able to exercise certain rights in relation to your personal data that we control and process. These are set out in more detail at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
You may request that we inform you of the data we hold about you and how we process it. This is your right to a Subject Access request. We will not charge a fee for responding to this request unless your request is clearly unfounded, repetitive or excessive in which case we may charge a reasonable fee or decline to respond.
We will, in most cases, reply within one month of the date of the request unless your request is complex or you have made a large number of requests in which case we will notify you of any delay and will in any event reply within 3 months.
If you wish to make a Subject Access Request, please send the request to firstname.lastname@example.org and your Request will be forwarded to your relevant Babyballet Franchisee.
- Communication Preferences
Every marketing email from a Babyballet Franchisee includes instructions on how to opt-out of receiving further marketing emails from Babyballet.
- Complaints and contact
All comments, queries and requests relating to our use of your information are welcomed and should be e-mailed to email@example.com and will then be forwarded on to the relevant Babyballet Franchisee.
We are committed to protecting your personal data but if for some reason you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.