RSVP Introductions Limited ("We") are committed to protecting and respecting your privacy.
This policy (together with any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller - A controller determines the purposes and means of processing personal data.
Data processor - A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data - Personal data and special categories of personal data
Personal data - The GDPR applies to 'personal data' meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data - The GDPR refers to sensitive personal data as 'special categories of personal data' (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party - means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
RSVP Introductions Limited is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: 23C Oakham Enterprise Park, Ashwell Road, Oakham, LE15 7TU. Tel: 01572 774880. Email: https://www.rsvp-int.co.uk/contact-us.php. For all data matters, contact our Data Protection Officer, contact details as above.
3. The purpose(s) of processing your personal data
We use your personal data for the purpose of taking steps to enter into or performing a contract for services.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
At the enquiry stage:
Personal data (name, email, address, phone, age, marital status, occupation).
When you make an appointment to meet us:
Personal data (height, weight, education, smoking, age range of potential partners, location of potential partners)
When you meet us:
Personal data (home owner, time at address, how long married/separated/divorced/widowed, dependant children, custody arrangements, nationality, hair and eye colour, employer, hobbies, interests, personality type, what you're looking for in a partner)
Special categories of data (country of birth, ethnic group, health history, criminal offences, strong political and religious views)
5. What is our legal basis for processing your personal data?
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
Processing is necessary for the performance of a contract for services with the data subject or to take steps to enter into a contract for services
b) Special categories of personal data (article 9 of GDPR)
Our lawful basis for processing your special categories of data:
Explicit consent of the data subject.
The form of consent is:
"I consent to you processing sensitive personal data I have disclosed on the Personal Profile Form to provide the Service."
If consent is not forthcoming or withdrawn, in order to perform the contract, our lawful basis for processing special categories of data will be:
Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law.
More information on lawful processing can be found on the ICO website.
6. Sharing your personal data
Your personal data will be treated as strictly confidential and will be shared only with service providers who work with us and on our behalf in the performance of the contract. These may include:
• Payment Providers (eg Sagepay)
• Events Venues (eg hotels, activity providers)
• Event Hosts
• Bulk Email Providers (eg Mailchimp)
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary for the periods and reasons shown below:
Type of record: Membership enquiries
Retention period: No expiry date or when requested
Where is it stored? Membership System
Reason: Re-enquiries, marketing and reference
Method of deletion: Deletion of personal data
Notes: The personally-identifiable elements of this data are only used for one year maximum for marketing. Thereafter, the data is only used for aggregate reporting internally. Re-enquiries are common in this industry.
Type of record: Interview Records on enquirers who did not join
Retention period: 6 years or when requested
Where is it stored? Network Drive or secure storage
Reason: Re-enquiries, comebacks, reference
Method of deletion: Deletion or Shredding
Notes: Comebacks are people who join some time after the interview, which is common in this industry.
Type of record: Membership and activity data on members
Retention period: Two years after contract termination or when requested
Where is it stored? Membership System, Network Drive
Reason: Performance of the lifetime contract, reactivations, disputes
Method of deletion: Deletion of personal data, deletion of interview record and contract docs.
Notes: By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after their last payment, for tax purposes.
8. Providing us with your personal data
We require your personal data as it is a requirement necessary to enter into a contract or to take steps to enter into a contract.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where your consent was the lawful basis for processing the data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
10. Transfer of Data Abroad
We may transfer limited personal data outside the EEA to service providers of international repute (eg Sagepay, Mailchimp).
11. Automated Decision Making
When matching, we automatically exclude members who do not match the search criteria of the member on whose behalf we are searching. This is exclusion is based on age, location and smoking. The significance is minimal and means we avoid wasting your time with matches that will not go ahead.
12. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
14. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact our Data Protection Officer using contact details in 2 above.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.