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Privacy notice

This privacy notice tells you what to expect us to do with your personal information in relation to the Lewes District Business Start-up programme, which is delivered by always possible in partnership with Lewes District Council.

Our contact details

always possible ltd is the data controller and responsible for your personal data. Our contact details are data@alwayspossible.co.uk or you can write to us at always possible ltd, 483 Green Lanes, London, N13 4BS.

Click here to read our full privacy policy.

Click here to read the Lewes District Council privacy policy.

What information we collect, use, and why

We collect or use the following information to provide services:

  • Names and contact details
  • Business address (if applicable)
  • Accessibility requirements (including dietary requirements, allergies and health conditions, as applicable)
  • Website user information (including user journeys and cookie tracking)

We also collect or use the following information to monitor equality and diversity:

  • Racial or ethnic origin (optional)
  • Gender (optional)

We collect or use the following information for service updates or marketing purposes:

  • Names and contact details
  • Marketing preferences
  • Location (to determine eligibility)
  • IP addresses
  • Website and app user journey information

We collect or use the following information to comply with legal requirements:

  • Health and safety information (if applicable)

Lawful bases

Our lawful bases for collecting or using personal information to provide services are:

  • Consent
  • Contract

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

  • Consent
  • Contract
  • Legitimate interest:
    • We may use publicly available business information to offer the free business support programme to eligible businesses that might benefit from it.

Our lawful bases for collecting or using personal information for legal requirements are:

  • Consent
  • Contract

Where we get personal information from

  • People directly
  • Councils and other public sector organisations
  • Publicly available sources

How long we keep information

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 or reporting requirements.

 

To decide 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 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.

Who we share information with

Data processors

Lewes District Council

As the funder of this programme, we will share registrant details, EDI information, and participant course progress with Lewes District Council for the purpose of monitoring contractual key performance indicators.

Hubspot

We use Hubspot as our contact database (CRM) and website host (CMS). When you fill out a form signing up for a course or wokshop, or to request access support or more information; your details are stored and processed within Hubspot. It is also used for sending marketing and/or one-to-one emails to update you about the programme.

Mighty Networks

Mighty Networks is the platform that hosts the The Possibility Club, where the course modules and resources can be accessed and completed. Only your email address, name and course progress will be processed here.

Other organisations

  • Organisations we’re legally obliged to share personal information with

Sharing information outside the UK

Where necessary, our data processors may share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place. Please contact us for more information.

Your data protection rights

Under data protection law, you have rights including:

  • Your right of access - You have the right to ask us for copies of your personal data.
  • Your right to rectification - You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
  • Your right to erasure - You have the right to ask us to erase your personal data in certain circumstances.
  • Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal data in certain circumstances.
  • Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.
  • Your right to data portability - You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.
  • Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent.
  • You don’t usually need to pay a fee to exercise your rights. If you make a request, we have one calendar month to respond to you.
  • To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

 

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:           

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Last updated

29 May 2024