1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, “we”, “us” and “our” refer to Robert Barrett, FloatAero and Formic Intelligent Training Labs.
- How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process, via third party data recording, specifically google analytics, data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is the google analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website.
2.3 We do not operate a user account process on our web site.
2.4 We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include details of your cycling performance data, height, weight and other personal statistic. The source of the service data is yourself with information / data disclosed by way of email, telephone or face to face communication.
Any personal data that is stored by FloatAero will be used wholly and solely in fulfillment of FloatAero contractual service obligations to the client. Email addresses are stored by default in the firstname.lastname@example.org address book and are covered by google’s data protection obligations. FloatAero do not send promotional emails. All FloatAero updates and promotions are issued via twitter and our Facebook page.
The legal basis for this processing is your consent as part of the performance of a service contract, between you and us, specifically in regard to cycling performance.
2.6 We undertake not to publish any of your personal data including the results of the processing of your data. We may approach individual clients to request that they consent to act as a reference customer or provide a testimonial. The final decision is always that of the client.
2.7 We may process information contained in any enquiry you submit to us regarding our services (“enquiry data“). The enquiry data may be processed for the purposes of responding to a request only. It will not be used for marketing or selling relevant goods and/or services to you.
2.8 We will not may process information relating to our customer relationships, including customer contact information (“customer relationship data“).
2.9 We may process information relating to transactions, including purchases of services, that you enter into with us. (“transaction data“). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
2.10 We do not operate a subscription email system or new letter system. Information about our services is published on our web site, as postings on our Facebook pages, or publicized using Twitter.
2.11 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.14 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.15 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.16 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
- Automated decision-making
We do not have any automated decision making capability.
- Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy. Currently we have no such associations or companies.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We will not disclose your personal data to any suppliers or subcontractors without your explicit consent in every instance. Note this will usually be name only when booking shared facilities.
4.4 Financial transactions in conjunction with our services do not involve us in having access to your personal information / banking information.
4.5 We will not disclose your enquiry data to any third parties.
4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- International transfers of your personal data
We will not transfer your personal data to any third parties.
- Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.3 We will retain your personal data as follows:
(a) Ride files will be stored on computers and back-up devices owned by us.
(b) Personal information and personal statistics (height, weight etc.) will be stored in Word, Excel or screen shot files and in some instances in traditional paper-based files. You can request that we delete some or all of the personal data that we have on record for you at any time. The deletion will occur as soon as reasonably possible after the time of the request.
6.3 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Security of personal data
7.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
7.2 We will store your personal data on personal computers and back-up devices, and in secure manual record-keeping systems.
7.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
- Your rights
9.1 In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
9.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
9.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
9.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
9.5 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by manual means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
9.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
9.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
9.13 You may exercise any of your rights in relation to your personal data by written notice to us or email.
- Third party websites
10.1 Our website may include hyperlinks to, and details of, third party websites.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
- Personal data of children
11.1 Our website and services are targeted at persons over the age of 18.
11.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
- Updating information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
- About cookies
14.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
14.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
14.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies that we use
Google Analytics (NID) to track user usage of the site.
WordPress – Accepting the Cookie notice (cookie notice accepted)
- Cookies used by our service providers
- Managing cookies
17.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
17.2 Blocking all cookies will have a negative impact upon the usability of many websites.
17.3 If you block cookies, you will not be able to use all the features on our website.
- Cookie preferences
- Our details
19.1 This website is owned and operated by Robert Barrett, with the trading styles of FloatAero and Formic Intelligent Training Labs.
19.2 Our principal place of business is at 2 Victoria Road, Ealing W5 1TB
19.4 You can contact us:
(a) by post, to the postal address given above;
(b) using any one of our website contact forms;
- Representative within the European Union
20.1 Our representative within the European Union with respect to our obligations under data protection law is ourselves.