Guide

PRIVACY POLICY

Welcome to the privacy policy of TrailMakerPRO (a trading name of INCONET Limited)

We respect your privacy and are committed to protecting your personal data. This privacy notice will tell you about how we look after your personal data when you deal with us or when you visit our website or use our app (regardless of where you visit it from), and tell you about your privacy rights and how the law protects you.

Purpose of this privacy notice

Please note that we do not knowingly collect data relating to children.

If you are a child and you think we have your personal data, please get in touch using the contact details on our web site.

This privacy notice aims to give you information on how we collect and process your personal data, including any information you may provide when you (for example):

Visit our websites
Communicate with us as a potential or actual user, client or host
Sign up to our newsletter/s
Participate in an event or activity using our app

It is important that you read this privacy notice, 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 data. This privacy notice supplements any of those other notices and is not intended to override them.

Who we are

INCONET Limited is a limited company, registration number, 03156209, and its registered address is Avalon, Newfields, Ellick Rd, Blagdon, Bristol, BS40 7TX, UK. It is the controller of your personal data and is responsible for the website on which this privacy notice appears.

Contact details

Our contact details can be found at:

www.trailmakerpro.com

You should address any enquiries to Adrian Boots, Director

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version of the privacy notice was last updated on 24 May 2021.

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.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name(s), last name and title (which may indicate marital status and gender).
Contact Data includes postal address (which may be your personal address), email address and telephone numbers.
Technical Data may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Survey Data includes your responses to any surveys we run.
Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We do not collect any "Special Categories" of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity Data, Contact Data and Transaction Data by filling in forms or by communicating with us by post, phone, email or otherwise. This includes personal data you provide when you:

enquire about becoming a host and providing events and activities via our app;
subscribe to our updates / newsletters;
request marketing information to be sent to you;
respond to an invitation to one of our events;
enter a competition, promotion or survey; or
give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where you have consented to it. (You have the right to withdraw consent to marketing at any time by contacting us.)

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose / activity	Type of data	Lawful basis for processing
To liaise with you about your potential or actual role as a client, host or user	• Identity Data • Contact Data • Survey Data	Consent
To manage our relationship with you which may include: (a) Notifying you about changes to or privacy notice (b) Asking you to leave a review or take a survey (c) Keeping you informed, for example via our newsletter or other updates	Identity Data • Contact Data • Survey Data • Marketing and Communications Data	Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study user, client and host preferences); alternatively, Consent
To enable you to partake in a prize draw, competition or complete a survey	• Identity Data • Contact Data • Survey Data • Marketing and Communications Data	Performance of a contract with you necessary for our legitimate interests (to study host, user and client preferences, to establish and promote TrailMakerPRO and other services)
To administer and protect our company, app, platform, other services, and our website/s (including troubleshooting, data analysis, testing, system maintenance, support, reporting	Identity Data • Contact Data • Technical Data	Necessary for our legitimate interests (for running our company, provision of administration and IT services, network)

Third-party marketing

We will get your express opt-in consent before we share your personal data with anyone else for marketing purposes. We do not currently have any plans to do this.

Opting out

You can ask us (or third parties) to stop sending you marketing messages at any time by contacting us – contact details are on our web site www.trailmakerpro.com

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 want 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, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 3 above.

Service providers acting as processors based in the UK or EU who provide IT and system administration services to us.

Professional advisers, including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities based in the UK, who require reporting of processing activities in certain circumstances.

We require all third parties 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.

International transfers

We do not knowingly share your personal data outside the UK or EU.

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 staff members, contractors and other third parties who have a need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We will notify you and any applicable regulator of any data breach where we are legally required to do so.

Data retention – how long will we use your personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are explained in more detail in the Glossary below.

Request access to your personal data.

Request correction of your personal data.

Request erasure of your personal data.

Object to processing of your personal data.

Request restriction of processing your personal data.

Request transfer of your personal data.

Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not normally have to pay a fee to access your personal data (or to exercise any of the other 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.

What we may need from you

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 to speed up our response.

Time limit to respond

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.

Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our company in conducting and managing our affairs to enable us to give our actual and potential hosts, clients and users the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means that you have freely given your consent to the processing of your personal data, in accordance with the relevant legal requirements.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or the legitimate interest of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain information to you or otherwise continue our relationship with you. We will advise you if this is the case at the time you withdraw your consent.