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1. Incorporation of Privacy Policy

1.1 Coventry City Council (‘the Council’) are committed to ensuring that your privacy is protected and is compliant with the Data Protection Act 2018 and the General Data Protection Regulations (EU) 2016/679 (GDPR). This privacy policy (‘Privacy Policy’) explains how the Council uses the information the Council collects about you and the procedures that the Council has in place to safeguard your privacy.

1.2 By using the Council’s website www.twofriargate.com (‘Website’), the Council is able to use the information it collects about you as a legitimate interest as defined in the GDPR. If you do not agree with the terms and conditions set out in this Privacy Policy, please ask us to delete all information held and do not continue to use the Website. Such requests can be made to Mark Mckeever, Director, Carousel, solutions@carouselmarketing.com.

1.3 For the purpose of the Data Protection Act 2018 and GDPR, the data controller is Coventry City Council.

2. The information the Council collects and how the Council uses it

2.1 When you visit the Website, register with the Website for updates, and/or request brochures offered on the Website you will have provided the Council with information including your name, postal address, e-mail address, telephone number, brochures obtained and such other relevant information which the Council deems necessary to provide you with the brochures and provide maintenance and support services. Where necessary, the information collected is transmitted in a secure manner to third parties listed at the end of this page to assist the Council to provide you with the brochures requested by you and to maintain the support services of the Council.

2.2 Subject to the terms and conditions of this Privacy Policy, the Council protects all personal data from being disclosed to any third parties except when required by law. In addition, the Council may use your information to assist in the prevention of unlawful activities e.g. intellectual property infringement or activities which threaten the Council’s Website or are adverse to your or the Council’s interest.

2.3 The Council may also use aggregate information and statistics, (but which will not contain your personally identifying information) for the purposes of monitoring your usage of the Website in order to help the Council develop the Website and the services offered by the Council. The Council may provide such aggregate information to third parties.

2.4 The Council may collect information which is based upon your behaviour and navigation on the Website. This information allows the Council to carry out internal research on the users’ interest, demographics and behaviour so that the Council can better understand, and in turn provide better information, products and services to you and other customers or members which may be of a Legitimate Interest to them, as defined by GDPR.

2.5 The Council may also wish to provide you with information the same service or any similar services or products the Council thinks may be of interest to you.

2.6 If you do not wish the Council to send you any information set out in Clauses 2.3 to 2.5 above, please send an e-mail to solutions@carouselmarketing.com

2.7 Subject to the other provisions of this Privacy Policy and such other provisions specified on the Website, the Council will not provide your information to other organisations or companies without your consent.

3. Use of cookies and other information gathering technologies

3.1 The Council uses ‘cookies’ and other technologies to collect information on site to assist the Council in monitoring the Council web page flow, promotional effectiveness as well as to promote trust and safety.

3.2 Certain features on the Website are only available if you enable the cookie. The Council  also uses a cookie to assist it to provide information that is relevant to your interest.

3.3 You are free to decline the Council’s cookies although that may impair certain features on the Website.

3.4 You can delete any cookies from your computer – refer to your internet browser’s help files.

3.5 The Council may also track certain information through the use of JavaScript code and third party website analytics providers.

3.6 More detailed information on why we use cookies, the cookies set by this website and third-party cookies is provided below:

Why we use cookies

Cookies are small text files stored on your computer while you are visiting a website. We use cookies to:

  • Make our websites work as you would expect
  • Offer you the best browsing experience
  • Provide us with anonymous aggregated information about how users interact with our website
  • Remember any preferences and settings you select when you visit our website again

In no other context do we use cookies to collect information that identifies you personally. Most of the cookies we set are automatically deleted from your computer when you leave our website, or shortly afterwards.

Complete information about the cookies we may set on your browser appears below.

Cookies set by this website

We use Google Analytics to add value and convenience to your experience of our website. Google Analytics sets several cookies on your browser. These cookies are used to collect information about how visitors use the website. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the website from and the pages they visited.

Cookie name: _ga
Service: Google Analytics
Expiry: 2 years
Purpose: Used to distinguish users.

Cookie name: _gid
Service: Google Analytics
Expiry: 24 hours
Purpose: Used to distinguish users.

Cookie name: _ga_<container-id>
Service: Google Analytics
Expiry: 2 years
Purpose: Used to persist session state.

4. Protecting your information

4.1 We do not control the use of these third-party cookies, and you should check Google’s privacy policy If you have concerns. Further information and how to opt-out can be found on Google’s website.

4.2 The internet is not a secure medium. However, the Council has put in place various security procedures and strict policy rules to safeguard and protect your information from unauthorised and unlawful access and use. These security procedures and policies, which are of the highest standards, are continuously improved.

4.3 Notwithstanding the above, it should be appreciated that no system is entirely foolproof and you should be careful when you reveal any confidential information to any third party.

5. Disclosure of your information

5.1 If the Council and/or part of its organisation is sold or integrated with another organisation, your details may be disclosed to the Council’s advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the Council.

5.2 The Council reserves the right to disclose your data (and you consent to such disclosure) if the Council is under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply the Council’s Terms and Conditions and/or this Privacy Policy, and other agreements; or to protect the rights, property, or safety of the Council, the Council’s customers or members. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

6. Updating your details

6.1 If any of the information that you have provided to the Council changes, for example if you change your email address, name or contact details or if you wish to cancel your membership as a registered user, please contact the Council by sending an email to solutions@carouselmarketing.com.

7. Other Terms

7.1 Owing to the global nature of the Internet infrastructure, the information you provide may be transferred in transit to countries outside the European Economic Area that do not have similar protections in place regarding your data and its use as set out in this Privacy Policy. However, the Council has taken the steps outlined above to try to improve the security of your information. By using the Website, you consent to these transfers.

7.2 The Council  supplies links to other websites. If you click on a link, you are not protected by this Privacy Policy and you are advised to read the privacy policy of the other website as they may differ from this Privacy Policy.

7.3 The Council reserves the right to amend this Privacy Policy from time to time as it deems necessary. In such event, the Council will post such changes on the Website.

7.4 The Council welcomes your views about the Website and its privacy policy. If you would like to contact the Council with any queries or comments please send an email to solutions@carouselmarketing.com.

External Third Parties

List of third parties we share your information with to provide you with the service you have requested:

  • Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Cloud-based website hosting providers based in the USA.
  • Campaign Monitor acting as processors based in Australia.
  • Mailchimp acting as processors based in the USA.
  • Dropbox acting as processors based in the Philippines.
  • LinkedIn acting as processors based in the USA.