Privacy Notice - Purposely

Purposely’s goal is to support founders to embed purpose into their business by using or considering the company limited by shares legal structure. As such, we provide a website application that you can use to create your company articles, and embed purpose into the DNA of your business.

Purposely is operated by Social Enterprise Coalition CIC (“Social Enterprise UK”), a UK registered company (company number 4426564), with the support of Bates Wells & Braithwaite London LLP (“Bates Wells”), a limited liability partnership registered in England and Wales (OC325522) (together, ‘we’, or ‘us’). 

This Privacy Notice applies to personal data processed by us on our website, https://getpurpose.ly, and gives you detailed information on (i) why and when we collect your personal data when you use our website, (ii) how we use your personal data, (iii) how we keep it secure, and (iv) how you can let us know if you would like us to change how we manage it. 

Table of contents

1. What is Personal Data?
2. Joint Controllers
3. The information we collect
4. How we use your personal data
5. Lawful Bases
6. Individual Rights
7. Sharing your personal data with third parties
8. Third party websites
9. International data transfers
10. Security of your information
11. How long we store your personal data for
12. Changes to this Privacy Notice
13. Complaints
14. How we use cookies
15. Contact us

What is Personal Data?

• Under the UK General Data Protection Regulation (Regulation (EU) 2016/679) and Data Protection Act 2018 (together “Data Protection Law”), personal data is defined as ‘any information relating to an identified or identifiable natural person’ (also known as a 'data subject’).
• Personal data does not include information where the identity of the individual has been fully and effectively removed (anonymous data). 

Joint Controllers

• A controller of personal data is the individual or legal person that determines how and why personal data is collected. In other words, it is the organisation who controls and is responsible for processing and protecting personal data in accordance with Data Protection Law.
• Bates Wells and Social Enterprise UK are joint controllers of personal data collected by the Purposely tool, as defined by Data Protection Law. This means we are both jointly responsible for handling that personal data. If you have any questions about your personal data or its use by us, please contact us using the details set out in the ‘Contact us’ section below. 

The information we collect

We may collect the following personal data about you:

• If you sign up to Purposely, we collect your name and email address.
• If you exchange emails, telephone conversations or other electronic communications with our staff members, our systems will record details of those emails or conversations, sometimes including their content and your contact details.
• When you contact us, we sometimes need to keep a record of the communication we have with you.
• As otherwise disclosed at the time of collection or use.

When you access our website, we also collect information about your computer, including, where available, your IP address, operating system, and browser type. We do this for system administration purposes, including to analyse trends and gather broad demographic information for aggregate use so that we can improve the site, and deliver customized, personalized content.

You are under no statutory or contractual obligation to provide us with your personal data. If you choose not to do so, of course, we may not be able to contact you. 

How we use your personal data

We may use your personal data for the following purposes:

• to enable you to create a Purposely account and to log into and use the platform for the benefit of your business.
• Contact you with important information relating to your account.
• Enable you to make use of our services.
• Send you updates and information about Purposely or related services that we think might be of interest to you.
• Learn from your experience and feedback to develop our work.
• Keep our database accurate, relevant and up to date.

We do not use automatic decision-making or engage in profiling. If a situation arises where we intend to use your personal data for any reason beyond and incompatible with its original purpose, we will notify you and provide additional information ahead of time.

We will not sell or distribute your information to third parties. We shall not use your personal data as part of our own general marketing activities.

Lawful Bases

We will only use personal data when the law allows us to (i.e. where we have a ‘lawful basis’). At least one of these must apply whenever personal data is to be processed:

• Consent: you have given free, specific, informed and unambiguous consent for your personal data to be processed for a specific purpose (for example, we may ask for your consent to send you marketing materials about Purposely). You may unsubscribe from our email communications at any time by emailing us at membership@socialenterprise.org.uk or by following the instructions in any email we send you.
• Contract performance: the processing is necessary for the performance of a contract you have with us, or in order for us to take steps at your request prior to entering into a contract.
• Compliance with legal obligation: the processing is necessary for us to comply with the law for tax, social security obligation and employment purposes (not including contractual obligations).
• Protection of vital interests: for example, where the processing is vital to an individual's survival.
• Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third-party and your interests and fundamental rights do not override our own. For example, we have a legitimate interest in making the Purposely tool available to you and administering your sign-up on the website.

Individual Rights

Your data subject rights are listed below:

• To request access to the personal data we hold about you;
• To request that we rectify or erase your personal data;
• To request that we restrict or block the processing of your personal data;
• To object to our processing of your personal data in certain circumstances; 
• Under certain circumstances, to ask us to port personal data about you that you have provided to us to you or a third party; and
• Where we previously obtained your consent (or are relying on consent to process your personal data), to withdraw consent to processing your personal data.

In order to exercise these rights, please email us at membership@socialenterprise.org.uk Please be aware that we may be unable to comply with your request under certain circumstances, for example if we are legally prevented from doing so or can rely on exemptions.  

Sharing your personal data with third parties

We may share your personal data with third parties, including the following:

• with contractors, suppliers, or other third parties that provide services on our behalf (such as website host providers);
• as part of a sale, merger or acquisition, or other transfer of all or part of our assets including as part of a bankruptcy proceeding;
• pursuant to a subpoena, court order, or other legal process or as otherwise required or requested by law, regulation, or government authority programs, or to protect our rights or the rights or safety of third parties;
• with our professional advisors, lawyers, accountants and auditors; or
• with your consent or as otherwise disclosed at the time of data collection or sharing.

Third party websites

Our site 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 any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

International data transfers

The data that we collect from you will be processed at our servers in the UK.

We do not currently transfer personal data we hold to a country outside the UK. If we do so, we will take steps to ensure that your personal data is protected in accordance with appropriate safeguards, especially where the recipient country is not considered to be adequate under UK law. In particular, we will rely on the appropriate safeguards under Data Protection Law, such as the UK International Data Transfer Agreement approved by the UK Government to protect your personal data. 

Security of your information

To help protect the privacy of personal data you transmit through use of this website, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities. That being said, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact us” section below.

How long we store your personal data for

We store your personal data in accordance with our data retention policy. This policy is reviewed and updated internally to ensure we do not store your data for longer than is necessary. We also review how and where we store any data to ensure that we meet our obligation to store data securely.

In addition, some of the data we hold may be subject to certain legal and regulatory obligations, which provide a minimum retention period for different types of data. The retention period varies depending on the data we hold.

The criteria used to determine the period of storage of personal data are:

• The respective statutory retention period;
• Our contractual and/or business relationships with you;
• Potential disputes; and
• Any guidelines issued by relevant data protection supervisory authorities.

After expiration of that period, the corresponding information is routinely securely deleted, as long as it is no longer necessary for the fulfilment of a contract, the initiation of a contract or to protect or defend our position or that of a third party. If you have any questions about retention periods, please contact us at membership@socialenterprise.org.uk.

Changes to this Privacy Notice

This Privacy Notice was last updated on 14 March 2023. We may vary this Notice from time to time, and such variations become effective on posting on this website – please check back from time to time. If we decide to make significant changes to our policy, we will contact you where reasonably possible.

Complaints

You have a right to lodge a complaint against us, which you can do by contacting the UK Information Commissioner’s Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website at  www.ico.org.uk/concerns.

How we use cookies

Our website uses cookies to enhance your experience while using the site. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Purposely services may not work properly.

For further details about our use of cookies, please visit our Cookie Notice here. 

Contact us

If you have any questions or concerns about this Privacy Notice or the way in which we handle your personal data, please contact us at: 

Social Enterprise UK
4th Floor
21 Prescot Street
London
E1 8BB