Privacy & Cookies Policy

Steady on Your Feet understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://www.steadyonyourfeet.org/ and any regional subdomains, eg: https://{region-name}.steadyonyourfeet.org/ (“Our Sites”) 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.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is requested when visiting our website, one of our regional websites, including starting our self assessment process through any of those means.

1. Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Assessment or Action Plan”	means a session made during the use of a Self Assessment or Action plan process and/or use certain areas and features of Our Sites;
“Cookie”	means a small text file placed on your computer or device by Our Sites when you visit certain parts of Our Sites and/or when you use certain features of Our Sites. Details of the Cookies used by Our Sites are set out in Part 14, below; and
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;

2. Information About Us

Our Sites is owned and operated by Better Brand Agency Limited a limited company registered in England under company number 06684268.

Registered address: Better Studio Plenary House, Queens Square, Middlesbrough, Cleveland, TS2 1PA

Data Protection Officer: Mark Easby.

Email address: mark@steadyonyourfeet.org.

Telephone number: +44(0)1642 989158.

Postal address: Better Studio Plenary House, Queens Square, Middlesbrough, Cleveland, TS2 1PA.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Sites. Our Sites may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5. What Are My Rights?

   Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

   1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
   2. The right to access the personal data we hold about you. Part 13 will tell you how to do this.
   3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
   4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 15 to find out more.
   5. The right to restrict (i.e. prevent) the processing of your personal data.
   6. The right to object to us using your personal data for a particular purpose or purposes.
   7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
   8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
   9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

   For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.

   It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

   Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

   If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

6. What Data Do We Collect and How?

Depending upon your use of Our Sites, we may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies and our Cookie Policy. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children.

Data Collected	What We Collect	How We Collect the Data
Identity Information	Name, email address	User input via forms (eg: Self Assessment and Action Plan)
Contact Information	regional location/area, email address	User input within the Self Assessment and Action Plan
Profile Information	Questionnaire responses, preferences, action plan notes, assessment follow up responses	User input via Self Assessment, Action Plan, and review process
Technical information	IP address, browser type, operating system	Collected automatically when visiting our websites

7. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful basis for doing so:

What We Do	What Data We Use	Our Lawful Basis
Setting up your assessment and action plan	Identity, Contact and Profile Information	Legitimate interest to enable us to provide the service to you, and tailor the assessment and action plan to your needs and wishes
Providing and managing your assessment	Profile Information	Legitimate interest to allow you to access the service.
Personalising and tailoring your experience	Identity, Contact, Technical and Profile Information	Legitimate interest to enable us to tailor the service to meet your needs and wishes
Administering across Our Sites	Identity, Contact, Technical and Profile Information	Legitimate interest to maintain the site and provide support
Providing additional services/products	Contact Information	Legitimate interest to allow the supply of additional services and products that you may request
Improving services	Identity and Profile Information	Legitimate interest to allow us to refine the additional services and products that you may find helpful
Communicating with you.	Profile Information	With your consent
Sending you email updates	Contact Information	With your consent (opt-in, can opt-out anytime)

Third Parties (including the National Health Service) whose content appears on Our Sites may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact [us] OR [me] using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will not be kept for longer than 24 months after you have ceased to use and engaged with the Assessment or Action Plan or Our Sites.

9. How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer personal data in or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office.

Please contact us using the details below in Part 15 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.

The security of your personal data is essential to us , and to protect your data, we take a number of important measures, including the following:

• limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and
• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

10. Do You Share My Personal Data?

 

11. How Can I Control My Personal Data?

1. In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Sites, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Assessment or Action Plan).
2. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12. Can I Withhold Information?

You may access certain areas of Our Sites without providing any personal data at all. However, to use all features and functions available on Our Sites you may be required to submit or allow for the collection of certain data.

You may restrict our use of Cookies. For more information, see Part 14 about Cookies.

13. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14. How Do You Use Cookies?

Our Sites may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Sites and to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Our Sites, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Sites for to enable us to link you to service providers who can supply you with relevant products and services. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Sites and your use and experience of Our Sites will not be impaired by refusing consent to them.

All Cookies used by and on Our Sites are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a pop up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Sites may not function fully or as intended.

Certain features of Our Sites depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Sites may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

The following first-party Cookies may be placed on your computer or device:

Name of Cookie	Purpose	Strictly Necessary
XSRF-TOKEN	This is a functional and required cookie which helps protect against cross-site request forgery (CSRF) attacks	Yes
steady_on_your_feet_session	This cookie is used to maintain your session on our Website	Yes
popup_warning	This is a functional and required cookie used to track whether you have seen and accepted our cookie warning	Yes
partner_id	This is cookie only used when you are referred by one of our trusted partners. We use this to track and assign any assessment you thereafter make, to that partner. To note, the partner are not able to see any of your data, including action plan items, notes or answers to your assessment.	Yes

and the following third-party Cookies may be placed on your computer or device:

Name of Cookie	Provider	Purpose
YouTube Cookies	Google (YouTube)	We embed YouTube videos on our website. YouTube may set cookies to track video views, store user preferences, and collect analytics data. These cookies may also be used for advertising purposes if you are signed into a Google account. For more information on YouTube’s cookies and how they are used, please visit Google’s Cookie Policy.

Our Sites uses analytics services provided by <<insert name(s) of analytics service provider(s)>>. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Sites is used. This, in turn, enables us to improve Our Sites and the products and services offered through it.

The analytics services used by Our Sites use Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Sites, it does enable us to continually improve Our Sites, making it a better and more useful experience for you.

The analytics services)used by Our Sites use the following Cookies:

Name of Cookie	First / Third Party	Provider	Purpose
_ga _ga_[id]	Third Party	Google	We use Google Analytics to collect information about how visitors use our website. This helps us understand website traffic, improve user experience, and analyze trends.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Sites more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Mark Easby):

Email address: mark@steadyonyourfeet.org.

Telephone number: +44(0)1642 989158.

Postal address: Better Studio Plenary House, Queens Square, Middlesbrough, Cleveland, TS2 1PA.

16. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be posted on Our Sites and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Sites following the alterations. We recommend that you check this page regularly to keep up-to-date.