Privacy Policy

1.

Introduction

1.1

Who are we

This is the Privacy Policy of PM Museum Ltd (trading as: ‘Museum of the Prime Minister’), registered company number SC747486 (“we”, “our”, “us”).

When we collect, store and process your Personal Data in accordance with this Privacy Policy, we are the Controller for the purpose of the Data Protection Laws.

1.2

Purpose of this policy

We are committed to safeguarding the privacy of our website visitors. In this Privacy Policy we explain how we will collect, store and process your Personal Data through your use of this website at https://www.museumofpm.org/ (the “Site”), including any data you may provide through this Site when you sign up to our newsletter or otherwise engage with our content.

This Site is not intended for children and we do not knowingly collect data relating to children.

It is important that you read and retain this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or Processing Personal Data about you so that you are fully aware of how and why we are using your personal data and what your rights are under Data Protection Laws.

This Privacy Policy supplements the other notices available on our Site and other platforms and is not intended to override them.

1.3

How to contact us

If you wish to speak to us or question anything in this Privacy Policy relating to how we collect, store or process your Personal Data, please contact us at the following:

Principal Address: Archibald Hope House, Eskmills Park, Station Road, Musselburgh, EH21 7PQ.

Email: info@museumofpm.org

Website Contact Form which can be accessed here.

1.4

Changes to this Privacy Policy

We may update this Privacy Policy from time to time by publishing a new version on our Site. It was last updated on [30 November 2023]. You should check this page occasionally to ensure you are happy with any changes to this Privacy Policy. We may notify you of changes to this Privacy Policy by email or other means of communication.

2.

Glossary of terms

  • When we refer to “Data Protection Laws” we mean (the United Kingdom’s Data Protection Act 2018 and the GDPR as it forms part of the law of the United Kingdom (“UK GDPR”), including by virtue of Section 3 of the European Union (Withdrawal) Act 2018, as any of the forgoing may be amended from time to time.
  • “Personal Data” is any information identifying you as a specific individual. It can identify you directly from that information alone or indirectly in combination with other information we hold or can reasonably access. As well as identifying you as a specific individual, to be Personal Data, the data must also relate to you. Truly anonymous information is not Personal Data.
  • “Processing” is almost anything that can be done with Personal Data, including collecting, recording, storing, using, analysing, combining, disclosing or deleting it.
  • “Special Category Personal Data” means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data.
  • “Criminal Convictions Data” means Personal Data relating to the alleged commission of offences by you; or proceedings for an offence committed or alleged to have been committed by you or the disposal of such proceedings, including sentencing.
  • A “Controller” is someone who decides why Personal Data is to be collected and how it will be used and treated.
  • “ICO” means the UK Information Commission’s Office, the UK supervisory authority for data protection issues.

3.

Lawful basis

We will only use your Personal Data when the law allows us to – this is referred to as a ‘lawful basis’. Most commonly, we will use your Personal Data in the following circumstances:

  • Consent: you have given your consent for us to process your Personal Data for that purpose.
  • Contract: the use of your Personal Data is necessary for the performance of a contract we have with you, or because you have asked us to take specific steps before entering into a contract.
  • Legal Obligation: the use of your Personal Data is necessary for us to comply with law.
  • Vital Interests: the use of your Personal Data is necessary to protect your or someone else’s vital interests (e.g. your or someone else’s life).
  • Legitimate Interests: the use of your Personal Data is necessary for legitimate interests pursued by us or a third party. Before we rely on this lawful basis we will balance your interests against the legitimate interests pursued by us. In particular, if you would not reasonably expect your Personal Data to be used in a certain way, or it would cause unwarranted harm, your interests are likely to override the legitimate interests. However, your interests do not always have to align with the legitimate interests.

We do not actively collect any Special Categories of Personal Data or Criminal Convictions Data.

4.

The type of personal data we collect and how we use it

In this Section 4 we have set out:

  • the types 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 basis of the Processing your Personal Data.

Identity and Contact Data:

We may process identity data such as your first name, maiden name, last name, username or similar identifier and also contact data including your billing address, delivery address, email address or telephone number (“Identity and Contact Data”).

We will use your Identity and Contact Data to manage our relationship with you, which may include providing you with our goods and/or services.

The source of the Identity and Contact Data will generally be you, unless another individual provides us with such information on your behalf.

The legal basis for this Processing is our legitimate interests, namely communicating with you and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

Usage Data:

We may process data about your use of our website and services (“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 system is only enabled with your explicit consent). This Usage Data may be processed for the purposes of analysing the use of the Site and services.

We ask for your consent before applying the tracking system but the legal basis for the Processing of data collected by the tracking system is our legitimate interests, namely monitoring and improving our Site and services.

Enquiry Data:

We may process information contained in any enquiry you submit to us regarding goods and/or services (which is likely to include Identity and Contact Data) (“Enquiry Data“).

The Enquiry Data may be processed for the purposes of offering, marketing, and selling relevant goods and/or services (both current and similar related goods and/or services in the future) to you.

The legal basis for this Processing is our legitimate interests, namely responding to your enquiry and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

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”).

The Notification Data may be processed for the purposes of sending you relevant notifications and/or newsletters. We will ask for your prior consent to sending these types of communications.

You can ask us to stop sending you email notifications and/or newsletters at any time by following any opt-out links on any relevant message sent to you or by contacting us at any time.

Where you opt-out of receiving these messages, this will not apply to Personal Data provided to us for other purposes.

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. Our Site will generate the metadata associated with communications made using the Site contact forms.

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 Site and business and communications with users; and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

Financial Data:

We may collect financial information from you such as bank account information to the extent that you purchase goods and/or services from us and/or to the extent that you make a donation to us (“Financial Information”).

We will ask you to provide such Financial Information to process your purchase and/or your donation.

Our legal basis for Processing your Financial Data will be for the performance of a contract with you where you have purchased goods and/or services from us or where you have made a donation, our legal basis shall be your consent to process such information.


Legal obligation, claims and insurance

We may process any of your Personal Data identified in this Privacy 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.

We may process any of your Personal Data identified in this Privacy Policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this Processing is our legitimate interests, namely the proper protection of our business against risks.

In addition to the specific purposes for which we may process your Personal Data set out in this Section, we may also process any of your Personal Data where such Processing 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.


Failure to provide information

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).


Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the Processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent where this is required or permitted by law.

5.

Sharing your personal data

We may disclose your Personal Data to any member of our company as reasonably necessary for the purposes, and on the legal bases, set out in this Privacy Policy.

In order to carry out the daily running and operations of our business, we may need to disclose your Personal Data to other businesses or third party suppliers. For example, these may be sub-contractors, online systems and software applications.

Specifically, we share your Personal Data with the following third parties in certain circumstances as detailed below:

Name or category of Third Party

Role of Third Party

Location of Third Party

Safeguards in place (if applicable)

Inuit Mailchimp (operated by Inuit Inc.) (“Mailchimp”)

Sign-up form for newsletter

USA

As detailed at section 7 below, we will ensure that appropriate safeguards are in place to ensure that the transfer of your Personal Data complies with Data Protections Laws.

A copy of Mailchimp’s privacy policy can be found here: https://www.intuit.com/privacy/statement/

Krystal Hosting Limited (“Krystal”)

IT and system administration. Krystal allow us to organise and un our business.

UK

As detailed at section 7 below, we will ensure that appropriate safeguards are in place to ensure that the transfer of your Personal Data complies with Data Protections Laws.

Many of Krystal’s third parties are based outside the UK and/or EEA. Details of the appropriate safeguards Krystal will put in place when transferring your data can be found within its privacy policy here: https://krystal.uk/legal/privacy-policy

Name or category of Third Party

Inuit Mailchimp (operated by Inuit Inc.) (“Mailchimp”)

Role of Third Party

USA

Location of Third Party

Sign-up form for newsletter

Safeguards in place (if applicable)

As detailed at section 7 below, we will ensure that appropriate safeguards are in place to ensure that the transfer of your Personal Data complies with Data Protections Laws.

A copy of Mailchimp’s privacy policy can be found here: https://www.intuit.com/privacy/statement/

Name or category of Third Party

Krystal Hosting Limited (“Krystal”)

Role of Third Party

UK

Location of Third Party

IT and system administration. Krystal allow us to organise and un our business.

Safeguards in place (if applicable)

As detailed at section 7 below, we will ensure that appropriate safeguards are in place to ensure that the transfer of your Personal Data complies with Data Protections Laws.

Many of Krystal’s third parties are based outside the UK and/or EEA. Details of the appropriate safeguards Krystal will put in place when transferring your data can be found within its privacy policy here: https://krystal.uk/legal/privacy-policy

We may disclose your Personal Data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Where we share your Personal Data with third parties, we require them to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.

Data security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7.

International transfers

In this Section we provide information about the circumstances in which your Personal Data may be transferred to countries outside the United Kingdom.

Some of our third parties are based outside the UK or the EEA and as such their Processing of your Personal Data will involve a transfer of data outside of the UK or the EEA. If we transfer your Personal Data to a third country we will take reasonable steps to ensure that the transfer is to a country covered by a decision of the ICO or is otherwise made in circumstances where we have put appropriate safeguards in place to protect your Personal Data in accordance with the Data Protection Laws, such as using specific contracts approved for use in the UK which give Personal Data the same protection it has in the UK.

8.

Retention

This Section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of Personal Data.

Personal Data that we process for any purpose or purposes shall not be kept for longer than is reasonably necessary for that purpose or those purposes.

Your enquiry data and correspondence data will usually be destroyed 6 months after we have dealt with your enquiry/correspondence unless it is required for an ongoing relationship that we may have with you.

Your notification data is retained for as long as you wish to receive relevant notifications and/or newsletters from us. If you opt-out we may be required to retain some of your data so that we can make sure that we do not contact you.

Your usage data does not usually identify you and therefore may be retained indefinitely without further notice to you.

In some cases it is not possible for us to specify in advance the periods for which your Personal Data will be retained. In such cases, we will determine the period of retention based on its necessity for the proper administration of our website and business and/or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

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.

In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.

Your Rights

In this Section, we have summarised the rights that you have under the Data Protection Laws. 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.

Your principal rights under data protection law are:

  • 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 to you a copy of your Personal Data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can request a copy of the Personal Data we hold by contacting us. Please note that we may in return request copies of valid identification.
  • 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. We may need to verify the accuracy of the new data you provide to us.
  • Right to erasure: in some circumstances you have the right to the erasure of your Personal Data without undue delay. Those circumstances include: a) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; b) you withdraw consent to consent-based Processing; c) you object to the Processing under certain rules of applicable data protection law; d) the Processing is for direct marketing purposes; and e) the Personal Data have been unlawfully processed.
    However, there are exclusions of the right to erasure. The general exclusions include where Processing is necessary: a) for exercising the right of freedom of expression and information; b) for compliance with a legal obligation; or c) for the establishment, exercise or defence of legal claims.
  • Right to restrict processing: in some circumstances you have the right to restrict the Processing of your Personal Data.
    Those circumstances are: a) you contest the accuracy of the Personal Data; b) Processing is unlawful but you oppose erasure; c) 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 d) 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.
  • 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: a) the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or b) 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.
  • Right to data portability: to the extent that the legal basis for our Processing of your Personal Data is:
    i) consent; or
    ii) 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.

  • Right to withdraw consent: 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 have the right to withdraw consent by contacting us using the contact details provided at Section 10. You may exercise any of your rights in relation to your Personal Data by contacting us.

You will generally not have to pay a fee to exercise any of your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10.

Third party websites

Our site may include hyperlinks to, and details of, third party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

We have no control over, and are not responsible for, the privacy policies and practices of third parties. When you leave our website, we encourage you to read the privacy policy of every website you visit.

11.

Changes to personal data

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

12.

Marketing

You can ask us to stop sending you marketing messages at any time by following any opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt-out of receiving these marketing messages, this will not apply to Personal Data provided to us for other purposes.

13.

Cookies and similar technology

In common with many other website operators, we may use standard technology called ‘cookies’ on our Site. Cookies are small text files that are placed on your devices. They are widely used to make websites and platforms work, or work more efficiently, as well as to provide information to the owner of platform. You can set your browser to refuse all or some browser cookies, or to alert you when platforms set or access cookies. If you disable or refuse cookies, please note that some parts of our Site may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.museumofpm.org/cookie-policy/

14.

Automated decision making

Automated decision-making takes place when an electronic system uses Personal Data to make a decision without human intervention. We do not envisage that any decisions will be taken about you using automated means, however we will notify you in writing if this position changes.

15.

Complaints

You have the right to make a complaint at any time to the ICO, the UK supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.

We may require to use any or all types of your Personal Data for complaint, grievance or litigation purposes depending on the specific nature of the complaint, grievance or litigation. We rely on the lawful basis of our Legitimate Interests for this purpose, and the additional condition of Legal Claims

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