The Free Speech Union Limited (Company Nº. 12324336) is a company registered in England and Wales.
The Free Speech Union (“the FSU”) understands that your privacy is important to you and that you care about how your personal data is used, and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
This policy applies both to our website and at any of our events.
The FSU (and trusted partners acting on our behalf) use your personal data:
to provide goods and services to you;
to make a tailored website available to you;
to manage any registered account(s) that you hold with us;
to verify your identity;
for crime and fraud prevention, detection and related purposes;
with your agreement, we also use your personal data to contact you electronically about products and services which we think may interest you;
for promotional and marketing purposes and to tailor and personalise products and services;
to train and manage our people and develop products and services;
for customer insight and market research purposes – to better understand your needs;
to enable us to manage customer service interactions (including refunds) with you, and
where we have a legal right or duty to use or disclose your information (for example in relation to an investigation by a public authority or in a legal dispute).
The FSU uses your personal data for electronic marketing purposes (with your consent) and may send you postal mail to update you on the latest FSU products and services. You have the right to opt out of receiving promotional communications at any time, by making use of the “unsubscribe” link in emails or by contacting us via the contact channels set out in this Policy.
Sharing data with third parties
In order to make certain services available to you, we may need to share your personal data with some of our service providers, particularly for delivery of goods and services and communications with you.
The FSU only allows its service providers to handle your personal data when we have confirmed that they apply appropriate data protection and security controls. We also impose contractual obligations on service providers relating to data protection and security, which mean they can only use your data to provide services to the FSU and to you, and for no other purposes.
Aside from our service providers, the FSU will not disclose your personal data to any third party, except as set out below. We will never sell or rent our customer data to other organisations for marketing purposes.
We may share your data with:
payment processing providers (such as GoCardless and Stripe) where necessary for payments
email service providers (such as Microsoft and Mailgun) where necessary for communications
governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so in order to comply with our legal obligations or to exercise our legal rights (for example in court cases), or for the preventions, detection and investigation of crime or prosecution of offenders, and to safeguard and protect our employees, customers or other individuals
To deliver products and services to you, it is sometimes necessary for the FSU to share your data outside of the European Economic Area. This will typically occur when service providers are located outside of the EEA, or if you are based outside of the EEA. These transfers are subject to special rules under data protection laws. If this happens, we will ensure that the transfer will be compliant with data protection law and all personal data will be secure.
In addition to the above, and with your explicit opt-in consent, we may share your data with third parties to facilitate customised ad campaigns on other platforms (such as Facebook).
How long do we keep your data?
We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest we will normally hold any personal data is six years.
What personal data do we collect?
The FSU may collect the following information about you:
your name, date of birth and gender;
your contact details: postal address including billing and delivery addresses, telephone numbers (including mobile numbers) and email address;
purchases, orders and subscriptions made by you;
your online browsing activities on our website;
your username and password(s);
your communication and marketing preferences;
your correspondence and communications with the FSU, and
other publicly available personal data, including any which you have shared via a public platform (such as a Twitter feed or Facebook page).
This list is not exhaustive and, in specific instances, we may need to collect additional data for the purposes set out in this Policy. Some of the above personal data is collected directly, for example when you set up an online account on our website, or send an email to us. Other personal data is collected indirectly, for example your browsing or shopping activity. We may also collect personal data from third parties who have your consent to pass your details to us, or from publicly available sources.
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
The FSU does not knowingly collect any Personal Identifiable Information from children under the age of 16. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts promptly to remove such information from our records.
How we protect your data
Our security measures include encryption of data, penetration-testing of systems and security controls which protect our systems from external attack and unauthorised access.
You have the following rights:
the right to ask for a copy of personal data that we hold about you;
the right (in certain circumstances) to request that we delete personal data held on you, where we have no legal reason to retain it;
the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you;
the right to opt out of any marketing communications that we may send you and to object to us using or holding your personal data if we have no legitimate reason to do so;
the right (in certain circumstances) to ask us to “restrict processing of data”, which means that we would need to secure and retain the data for your benefit but not otherwise use it (the right to restrict processing); and
the right (in certain circumstances) to ask us to supply you with some of the personal data we hold about you in a structured machine-readable format and/or to provide a copy of the data in such a format to another organisation (the right to data portability).
If you wish to exercise any of the above rights, please contact us using the contact details set out below.
Legal basis for using data
Generally, the FSU collects and uses customers’ personal data because it is necessary for:
the pursuit of our legitimate interests (as set out below);
the purposes of complying with our duties and exercising our rights under a contract for the sale of goods to a customer, or
complying with our legal obligations.
In general, we only rely on consent as a legal basis for processing personal data in relation to sending direct marketing communications to customers via email or text message. Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process data after consent is withdrawn.
Our legitimate interests
The normal legal basis for processing customer data, is that it is necessary for the legitimate interests of the FSU, including:
selling and supplying goods and services to our customers;
protecting customers, employees and other individuals and maintaining their safety, health and welfare;
promoting, marketing and advertising our products and services;
sending promotional communications which are relevant and tailored to individual customers;
understanding our customers’ behaviour, activities, preferences, and needs;
improving existing products and services and developing new products and services;
complying with our legal and regulatory obligations;
preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
handling customer contacts, queries, complaints or disputes (including managing refunds);
managing insurance claims by customers;
protecting the FSU, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to the FSU;
effectively handling any legal claims or regulatory enforcement actions taken against the FSU;
fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.
Data protection officer
Our Data Protection Officer helps us to ensure we protect the personal data of our customers (and others) and comply with data protection legislation.
If you have any questions about how the FSU uses your personal data that are not answered here, or if you want to exercise your rights regarding your personal data, please contact our Data Protection Officer using the following means:
telephone, at +44 (0)20 3920 7865;
email, at [email protected], or
post, at Data Protection Officer, The Free Speech Union Limited, 85 Great Portland Street, London W1W 7LT.
You have the right to lodge a complaint with the Information Commissioner’s Office. Further information, including contact details, is available at https://ico.org.uk.
We may update this policy from time to time. You are strongly encouraged to read this policy and check back regularly. This policy was last updated in June 2020.