Privacy

Privacy Policy 2018

  • Introduction
  • What types of personal data do we use?
  • Where will we collect personal data from?
  • Who do we share your data with?
  • How do we use your data?
  • How to contact us?

 


  • Introduction

 

We are Cloud Nine Incentives LTD.  This privacy notice is to let you know how we promise to look after your personal data. This notice explains how we do this and tells you about your privacy rights and how the law protects you.
Cloud Nine Incentives Limited, Registered in England and Wales No. 07342147. Registered Office: 1 Mercers Manor Barns, Sherington, Newport Pagnell, Bucks, MK16 9PU, VAT no. GB 106 1084 58.
You can find out more about us at http://www.uponcloudnine.co.uk
If you have any questions or want more details about how we use your personal data, please let us know. Get in touch with our data officer, Sophie Chambers, on dataprotection@uponcloudnine.co.uk.

  • What types of personal data do we use?

Personal data for you and your emergency contacts

  • Name, address, date of birth, and email address

Special types of data
The law and other regulations treat some types of personal data as special. We will only collect and use these types of data if the law allows us to do so:

  • Health data and gender 
  • Where will we collect your personal data from?

 

Personal data will be collected when necessary to fulfil a prize.

  • Who do we share your data with?

Cloud Nine Incentives Limited only share data with suppliers to book travel arrangements or fulfil a prize.  Your permission will have been sought to make this possible.

  • How do we use your data?

 

Data Protection law says that we can use personal data only if we have a proper reason to do so. This includes sharing it outside of Cloud Nine Incentives. The law says we must have one or more of these reasons:

  • To fulfil a contract we have with you
  • When it's our legal duty
  • When it's in our legitimate interest
  • When you consent to it.



A legitimate interest is when we have a legitimate business or commercial reason to use your information. But even then, it must not unfairly go against what is right and best for you. If we rely on our legitimate interest, we will tell you what that is.
Below is a list of all the ways that we may use your personal data, and which of the reasons we rely on to do so. Our legitimate interests are also below
Serving our customers and clients
What we use your personal data for:

  • To deliver and manage a prize or incentive.
  • To manage our relationship with you.
  • To keep our clients who have opted in up to date with company news.
  • To develop and carry out marketing activities

Our reasons:

  • Your consent
  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty

Our legitimate interests:

  • Keeping our records up to date
  • Developing products and services, and what we charge for them
  • Seeking your consent when we need it to contact you
  • To provide you with information about your prize or incentive
  • As an active client to keep you informed about our latest events and competitions
  • Being efficient about how we fulfil our legal and contractual duties

Operating our business effectively
What we use your personal data for:

  • To run our business in an efficient and proper way. This includes managing our business capability, financial position, communications, corporate governance, planning, and audit.

Our reasons:

  • Our legitimate interests
  • Our legal duty

Our legitimate interests:

  • Complying with regulations that apply to us
  • Being efficient about how we fulfil our legal and contractual duties

Developing our products and services
What we use your personal data for:

  • To develop and manage our range of services
  • To ensure our service levels are as expected.
  • To ask how we can do things, differently or improve our services.

Our reasons:

  • Fulfilling contracts
  • Our legitimate interests
  • Our legal duty

Our legitimate interests:

  • Keeping our records up to date
  • Developing products and services, and what we charge for them
  • Seeking your consent when we need it to contact you
  • To provide you with information about your prize or incentive
  • As an active client to keep you informed about our latest events and competitions
  • Being efficient about how we fulfil our legal and contractual duties

How long will we keep your personal data?
We will keep your personal data for the duration of your prize-winning experience.  This means until your prize is fulfilled (you have travelled, received your prize etc.
In some instances, if your personal data appears on an financial statement relating to your prize we are required by law to keep these records for 7 years.
What data:

  • Personal data throughout your prize-winning experience and for up to 12 months after.

Our reasons:

  • Keeping our records up to date.
  • To respond to any questions, claims or complaints
  • Complying with regulations that apply to us
  • Being efficient about how we fulfil our legal and contractual duties

For very good reasons, we may keep your data for longer than the periods provided, such as if you were unfortunately involved in a safety incident. If we cannot delete it for legal, regulatory, or technical reasons, we will make sure that your privacy is protected and only use it for those purposes.

Do you want us to share what personal data we have about you, with you?
If you want us to share what information we have about you, please let us know. Get in touch with our data officer, Sophie Chambers, on dataprotection@uponcloudnine.co.uk
If you do want to contact us, it would be helpful for us to complete your query if you provide us with your address, contact details and what you would like to have a copy of.
Sometimes you may be asked to provide proof of identity before we show you your personal data – this helps us prevent unauthorised access.
Is the personal data we have about you incorrect?
You have the right to question any information we have about you that you think is wrong or incomplete. Get in touch with our data officer, Sophie Chambers, on dataprotection@uponcloudnine.co.uk
If you do, we will take reasonable steps to check its accuracy and correct it.
Do you want us to stop using your personal data?
You have the right to object to certain ways that we use your personal data, or to ask us to delete, remove, or stop using your personal data if there is no need for us to keep it. This is known as the ‘right to object’ and ‘right to erasure’, or the ‘right to be forgotten’.
In some cases, there will be legitimate, legal, or other official reasons for us to keep your data. But please tell us if you think that we should not be using it.
It may be possible for us to restrict the use of your data. This means that it would only be used for certain activities, such as legal claims or to exercise legal rights. If this was to happen, we would not use or share your information in other ways while it is restricted.
You can ask us to restrict the use of your personal data if:

  • It is not accurate
  • It has been used unlawfully but you don’t want us to delete it
  • It’s not relevant any more, but you want us to keep it for use in legal claims
  • You have already asked us to stop using your data but you are waiting for us to tell you if we can keep on using it

If you want to object to how we use your data, ask us to delete it or restrict how we use it, please get in touch with our data officer, Sophie Chambers, on dataprotection@uponcloudnine.co.uk

Do you want to withdraw your consent or object to when we use our legitimate interest for marketing?
Clients can withdraw your consent or object to marketing at any time. If this is the case, you can do this by:

If you withdraw your consent, we may not be able to provide certain products or services to you. If this is so, we will tell you.

  • How to contact us?

If you have any questions or want more details about how we use your personal data, please let us know. Get in touch with our data officer, Sophie Chambers, on dataprotection@uponcloudnine.co.uk
You also have the right to complain to the Information Commissioner’s Office. You can use the relevant section of the Information Commissioner's Office website to do this.