Thenetwalk.life® by The Dot Life Limited
This policy is effective as of 01 June 2020.
At Thenetwalk.life® by The Dot Life Limited, we are committed to respecting and protecting your online privacy. This includes your right to know what we do with the personal information you share with us. It also guides our policies regarding the management of your data, including how the information is collected, how it is processed, and for what purposes.
We will try and communicate our policies and procedures with you clearly and clarity. As such, this policy covers the following key areas:
1. Background Information
Thenetwalk.life® by The Dot Life Limited is a UK based business that ultimately oversees the delivery of TThenetwalk.life® events across the world (initially UK based). Each of Thenetwalk.life® event has a relationship with The Dot Life Limited (typically through a licence agreement, franchise or subsidiary status) that grants it the right to manage local Thenetwalk.life® events. As part of that relationship, Thenetwalk.life® by The Dot Life Limited collects, manages, and processes all associated data and is therefore considered the data controller for all Thenetwalk.life® by The Dot Life Limited group companies and all Thenetwalk.life® by The Dot Life Limited events worldwide.
Our designated Data Protection Officer is Andrew Metcalfe (COO, Thenetwalk.life® by The Dot Life Limited).
2. Why We Need Your Data
In order to support our network of Thenetwalk.life®events we need to know who is participating. We need to know this information so as to understand how we impact the communities we operate in, and also who participates within our events and when. The enables us to improve our events, provide adequate health and safety measures, and to ensure that we do not adversely aftect the areas in which we operate.
The General Data Protection Regulation (GDPR) and Data Protection Act 2018 (DPA) require that all information we collect must be done so under a specific lawful basis. There are six clearly-defined lawful bases for processing information, and we categorise the majority of our data processing under three of those: Contract, Legitimate Interests and Consent.
When you register for Thenetwalk.life® by The Dot Life Limited we need certain information about you to enable us to provide you with the service of walking at our events, and to ensure those events are delivered to an appropriate standard, and to allow us to provide you with accurate records of your participation.
2.2. Legitimate Interests
Outside of your direct participation we also wish to develop the reach and impact of our events and as such have a legitimate interest to process certain information with this aim. This includes things like carrying-out research to further understand who is or isn’t participating in our events (in order to understand our ability to impact those most in need) or capturing and sharing images of our events taking place, helping us to inspire other people to engage in physical activity and redefine what it means to be active.
Above and beyond simple participation as a walker there are a number of ways you can help us to ensure our events positively impact the health and happiness of their local communities
One of the best ways to support us in this way is by consenting to receive emails regarding things like milestone t-shirts, event profiles, offers, competitions and emails from our partners, training tips, and more. We therefore provide the opportunity at registration, and via your profile, to opt in to these communications. You can opt out at any time.
Due to GDPR requirements for providing consent, we do not process any data on children under the age of 13 if it would require consent as the lawful reason for processing. For this reason, children under the age of 13 do not have the option to opt in to the above emails.
2.4. Other Bases
Although extremely rare, there can be occasions where we are required to process information under one of the other three lawful bases: Legal Obligation, Vital Interest, Public Task.
3. Categories of Data
We utilise the following definitions for the types of data we collect:
3.1. Profile & Identity
Thenetwalk.life® by The Dot Life Limited ID, password, participation instances, date of birth, full name, images, postcode (not used for purposes of contact), marketing preferences, third party linking information.
Email address, address, phone number.
IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, records of pages visited and other information about the devices you use to access the site.
As part of our continual review of incidents at Thenetwalk.life® by The Dot Life Limited events we maintain a record of relevant details.
Any data submitted to us as part of research activities.
3.6. Event Imagery
Filming and photography captured at our Thenetwalk.life® events.
4. What Data We Collect
There are a number of ways where either you are able to explicitly share data with us or we are able to collect it as a result of your actions:
4.1. At registration
We collect information about you that allows us to support your participation in our events. We use this information to create a profile for you on our database, to which we can connect instances that in turn track your progress toward various Thenetwalk.life® by The Dot Life Limited participation milestones.
4.2. Using your profile
You can update information on your profile section on the website.
4.3. By linking your Thenetwalk.life® by The Dot Life Limited account with a third-party account
such as by connecting your Thenetwalk.life® by The Dot Life Limited profile with Strava you can connect services that you use.
4.4. Research Surveys
From time-to-time we send out research surveys that allow us to develop an understanding of Thenetwalk.life® by The Dot Life Limited and its members.
4.5. Partner surveys
Sent out by us, help to support our sponsors in understanding their level of connection with the Thenetwalk.life® by The Dot Life Limited communities they support.
When you visit our websites, cookies will be stored on your computer. Generally, cookies and similar technologies work by assigning to your browser or device a unique number that has no meaning outside of Thenetwalk.life® by The Dot Life Limited. We use these technologies to personalise your experience and to assist in delivering content specific to your interests. Additionally, after you’ve entered your Thenetwalk.life® by The Dot Life Limited ID and password we save that information so you don’t have to re-enter it repeatedly. Most browsers automatically accept cookies.
To manage the collection of information through cookies or other equivalent technology you can use the settings on your browser or mobile device.
4.7. Log Files
The collection of information: Every time you connect to Thenetwalk.life® by The Dot Life Limited websites your IP (Internet Protocol) address registers on our servers. Your IP address reveals no information other than the number assigned to you. We do not use this technology to obtain any personal data against your knowledge or free will (i.e. automatically recording email addresses of visitors). Nor do we use it for any purpose other than to help us monitor traffic on our website, or (in case of criminal activity or misuse of our information) to cooperate with law enforcement.
4.8. Social Media
4.9. Event Photography and Filming
Photography or filming is likely to take place at our events, is common practice, and helps us to inspire other people to engage in our events. It also provides a means for historical recording of our events over time. Furthermore, our use of images helps to demonstrate diverse groups of people engaging in both during Thenetwalk.life® by The Dot Life Limited events but also as part of the wider community.
We ensure compliance with safeguarding laws and are supported both in-house through our Safeguarding Lead and externally with the support of other experts in the field of safeguarding.
In line with the lawful basis of Legitimate Interest individuals have the right to object to this method of data processing by contacting the event team directly, or Thenetwalk.life® by The Dot Life Limited head office, and requesting deletion of relevant imagery. At event-level we will also seek, where the event is informed in on the day, not to photograph those individuals who have previously objected.
In exceptional circumstances, such as for our participants within the custodial system, we allow/require participants to register under a pseudonym. If you have any questions on this process please contact us via support.
5. What Data We Share
5.1. Publicly Available Information
We do not offer privacy settings in relation to your walking, and as such our websites display your name, participation locations, and KM walked. We do, in some cases, share (under the lawful basis of legitimate interest) this publicly-visible data with third parties.
5.2. Third-Party Connections
Across Thenetwalk.life® by The Dot Life Limited territories we offer a number of opportunities for our members to connect their Thenetwalk.life® by The Dot Life Limited accounts with other accounts in their name. This could be for the purposes of linking to activity tracking platforms, or sending activity data to incentivised wellness programmes. This can only happen at the request of the user, the specific data shared is clearly defined, and the integration can be stopped at any time by the user simply opting out.
5.3. Anonymised Participant Data
5.4. Personal Contact Details
We do not share our users’ personal contact details with any third parties. All communications sent to our database on behalf of our partners are sent directly by us and only where you have consented for us to do so.
6. How We Contact You
The large majority of our outgoing communication, to the Thenetwalk.life® by The Dot Life Limited community, is via email. Sending an email to you is a form of data processing, and as such may only be carried out under a specific lawful basis.
6.1. Under the Lawful Basis of Fulfilling a Contract
In order to fulfil our obligation to you as a Thenetwalk.life® by The Dot Life Limited, to ensure our events are delivered in a safe and appropriate manner, and to ensure the Thenetwalk.life® by The Dot Life Limited organisation is managed appropriately, there are some communications we send to everyone. The following communications fall into this category:
Confirmation you have registered with us.
Confirmation that your participation has been recorded by the local event team.
Notification that you have joined a Thenetwalk.life® by The Dot Life Limited milestone club and are eligible to claim any associated items such as t-shirts, wristbands, or certificates.
For those who have signed up to volunteer at a specific Thenetwalk.life® by The Dot Life Limited event, emails from that event team relating to that volunteering situation.
6.2. Under the Lawful Basis of Legitimate Interest
There are some occasions where we may contact you as part of our mission to make the world healthier and happier. For example, where we write to people who’ve registered but not participated, with the aim of understanding why and then being able to create a more supportive environment. The following types of communications fall into this category:
Questionnaires aimed at developing our understanding of who is participating.
Emails sign-posting participants to peer-support groups we feel may be suitable based on information you have provided.
Questionnaires for research aimed at understanding the effect of Thenetwalk.life® by The Dot Life Limited on global health and wellbeing.
You have a right to object to receiving these emails, to do that please contact us directly.
6.3. Under the Lawful Basis of Consent
Not only is our mission statement focussed on improving the health and happiness of our communities, but we have also made a commitment that participation in Thenetwalk.life® by The Dot Life Limited will be free, forever, for everyone. There are ways in which we rely on Thenetwalk.life® by The Dot Life Limited to achieve both of those ambitions, some of which require us to be able to send certain communications. We therefore offer all Thenetwalk.life® by The Dot Life Limited the chance to opt-in (at registration or via their profile) to receive regular updates from us and our partners.
Consent can be withdrawn at any time but does not apply to processing that happened before the consent was withdrawn.
Individual Thenetwalk.life® by The Dot Life Limited can also opt in to receive local volunteer appeals from the events of their choice. This can be amended at any time.
7. How We Protect Your Information
We work extremely hard to apply appropriate security measures in order to protect your data from being accessed or disclosed without your permission, or lost. We have a relatively small staff team, who are regularly updated on good practice in data handling, all personal data is password protected and only available to those with a specific need for access.
In the event of a data breach we will notify you and any applicable regulator, where legally required to do so. At local event level we ask our teams to support all participants (members, franchisees and volunteers) using their official email account (which we also maintain control of centrally). As such, the only personal information event teams hold on their participants is an email address if an email has previously been sent to the event email account. All leaders email accounts are password protected.
Some event leaders also use Facebook to communicate with participants, in these cases we retain admin control centrally and are able to control/remove access when required.
7.1. Third Country Data Transfers
On occasion we may use third parties for the purposes of data processing, and these may reside outside of the European Economic Area (EEA). These third parties are selected only if they exist in a territory deemed compliant with relevant legislation (read more) or with regards to third parties based in the US they must be part of the Privacy Shield (read more).
8. Retention Periods
In order to present our data retention periods as simply as possible we have chosen to do so using our definitions of categories of data defined in section 3 above.
8.1. Profile & Identity Data – In perpetuity
This is in order to maintain historic records of participation, to allow members to access their records, and to allow anyone who is registered with us to join in at any future Thenetwalk.life® by The Dot Life Limited event without the requirement to re-register.
8.2. Contact Data – Ten years from most recent participation instance
It is common for people to leave significant time periods between walking or volunteering at our events. It is also common for people to enjoy receiving our communications without participating at our events themselves.
8.3. Technical Data – Three years from point of data collection
In order to provide the best possible service to our users, to support the administration of our systems and processes, and to comply with legal obligations.
8.4. Incident Data – In perpetuity
We retain this data in order to keep a historical record of our incident profile, from which we are able to continually review our operating policies in order to enable the safe and appropriate delivery of our events.
8.5. Survey Data – In perpetuity
This data is used for the purposes of understanding our community in greater detail. Changes over time are of particular interest where comparison of current versus historical data allows us to assess the impact of our events and associated interventions.
8.6. Event Imagery – In perpetuity
Event imagery is predominantly processed under the lawful basis of Legitimate Interest, and may be stored securely by event teams in perpetuity as it represents a historical record of that event. Although extremely rare, there can be occasions where we are required to process information conveyed in photographs under another of the lawful bases, such as Legal Obligation, Vital Interest, Public Task.
9. Automated Decision Making and Profiling
In some situations we make automated decisions based on various types of data that we hold, this also also known as profiling. Examples of where we use this might be to send research surveys to people who have only ever participated once or to market products to specific demographics of people, such as advertising a local running event to Thenetwalk.life® by The Dot Life Limited in that area.
Whilst our automated decision making processes do not have a legal or similarly significant effect on the individuals concerned, you do have the right to object to us applying these processes to your data.
To understand more about automated decision making and profiling please see this section of the ICO website.
10. Your Rights
You have the right to:
10.1. Be informed if your personal data is being used
10.2. Get copies of your data
You are also free, at any time, to request a downloadable copy of all the data we hold on you. This would include details of all your walking and volunteering instances and as such is something we particularly recommend prior to any request for us to delete your data. To do this please contact us.
10.3. Have your data corrected
If at any time you feel the data we hold on you is incorrect, and you are unable to change it via your profile, please contact us.
10.4. Have your data deleted
Should you wish, at any time, for us to delete your data then please contact us via support and we can enable this process. Please note that this is not something that can be undone and as such we would recommend downloading your historical results (see next section) before doing so.
Although we approach every request for deletion on a case-by-case basis, we do not as a rule remove volunteer data simply on request. This is in order support potential future challenges, enquiries, or investigations where this information may be critical.
10.5. Limit how we use your data
If you are concerned about the accuracy of the data or how it is being used please contact us. Where you have previously provided us with consent to use your personal data in a specific way, you can remove your consent at any time (or opt-out) via your Thenetwalk.life® by The Dot Life Limited profile page.
10.6. Data portability
Following from point 10.2 (above) we will provide copies of your data in standard machine-readable formats. In such cases, please contact us.
10.7. Object to the use of your data
Where we are processing your data under the lawful basis of Legitimate Interest you have the right to raise an objection to that processing. This is not an absolute right to object and we will carry out a balancing test where we assess the reasons for your objection in the context of our legitimate interests.
10.8. Raise a concern
If, at any time, you have a concern as to how we are handling your information then please contact us. If you feel that we have not addressed your concerns appropriately you have the right to raise them directly with the ICO (read more).