1. Introduction and General Terms
50connect.co.uk is part of the Olderiswiser Media Limited group of websites.
Olderiswiser Media Limited is committed to protecting you and your family’s personal information when you are using Olderiswiser Media Limited services. We want our services to be safe, enjoyable and informative environments for visitors and members.
In order to provide you with the full range of Olderiswiser Media Limited services, we are sometimes required to collect information about you.
- What information Olderiswiser Media Limited may collect about you;
- How Olderiswiser Media Limited will use information we collect about you;
- When Olderiswiser Media Limited can use your details to contact you;
- Whether Olderiswiser Media Limited will disclose your details to anyone else;
- Your choices regarding the personal information you have provided to us;
The websites contain hyperlinks to other online properties owned and operated by third parties. These third party websites have their own privacy policies, including cookies, and we urge you to review them. They will govern the use of personal information you submit or are collected by cookies whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.
2. What information will Olderiswiser Media Limited collect about me?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity or Contact Details by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- create an account on our website;
- subscribe to our service or publications;
- request marketing to be sent to you;
- leave a comment on an article;
- enter a competition, promotion or survey; or<
- give us some feedback.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out:
- Technical Data from the following parties:
- analytics providers such as Google, Clicky, Bing, Infusionsoft based outside the EU;
- advertising networks such as Collective Media, Appnexus and Switch based inside the EU; and
- search information providers such as Google and Bing based inside OR outside the EU.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
3. How will Olderiswiser Media Limited use the information they collect about me?
Olderiswiser Media Limited will use your personal information for a number of purposes including the following:
- For “service administration purposes”, which means that Olderiswiser Media Limited may contact you for reasons related to the service you have signed up for, as set out in paragraph 4 below (e.g. to provide you with password reminders or to notify you that a particular service has been suspended for maintenance);
- to contact you about a submission you have made to the websites, including any content you provide.
- to personalise the way 50connect.co.uk content is presented to you (e.g. if we notice that the first thing you look at when you visit the website is ‘Entertainment’, then we may present this information or a link to it on your homepage);
- IP addresses are used to identify the location of users, the number of visits from different countries and also to block disruptive use; and
- to analyse and improve the services offered on 50connect.co.uk. e.g. to provide you with the most user-friendly navigation experience.
Where Olderiswiser Media Limited needs to use your personal information we will obtain your consent first. Otherwise, by providing us with the information either verbally, written or using our website, you consent to the collection, use and processing of this information by Olderiswiser Media Limited. We will use every reasonable effort to safeguard your personal information. You also have the option to withhold your information by written notification to us.
4. When will Olderiswiser Media Limited contact me?
Olderiswiser Media Limited may contact you:
- in relation to the functioning of any service you have signed up for in order to ensure that Olderisiwser Limited can deliver the services to you;
- where you have opted to receive further correspondence;
- in relation to any contribution you have made to 50connect.co.uk, e.g. in the site’s forum;
- to invite you to participate in surveys about Olderiswiser Media Limited services (participation is always voluntary); and
- for marketing purposes where you have specifically agreed to this (see paragraph 5 below)
Local pages will give you detailed information about how Olderiswiser Media Limited will contact you in relation to specific services.
5. Will I be contacted for marketing information?
You have the option to decline to receive marketing information from us by “opting out” with written notification to us or by visiting the newsletter preference centre.
6. Will Olderiswiser Media Limited share my personal information with third parties?
We will keep your information confidential except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies) or as described in paragraph 7 below. Generally, we will only use your information within Olderiswiser Media Limited. However, sometimes Olderiswiser Media Limited uses third parties to process your information. Olderiswiser Media Limited will require these third parties to comply strictly with its instructions.
7. Offensive or inappropriate content on the websites of Olderiswiser Media Limited
If you post or send offensive, inappropriate or objectionable content anywhere on or to 50connect.co.uk, or otherwise engage in any disruptive behaviour on 50connect.co.uk, Olderiswiser Media Limited may use your personal information to stop such behaviour.
Where Olderiswiser Media Limited reasonably believes that you are or may be in breach of any of the laws of England or Wales (e.g. because content you have posted may be defamatory), Olderiswiser Media Limited may use your personal information to inform relevant third parties such as your employer, school e-mail/Internet provider or law enforcement agencies about the content and your behaviour.
8. What if I am a user aged 16 or under?
If you are aged 16 or under, please get your parent/guardian’s permission beforehand whenever you provide personal information to Olderiswiser Media Limited’s website. Users without this consent are not allowed to provide us with personal information.
9. How long will Olderiswiser Media Limited keep my personal information?
We will hold your personal information on our systems for as long as is necessary for the relevant service, or as long as is set out in any relevant contract you hold with Olderiswiser Media Limited. In the case that you wish to cancel your registration as a 50connect.co.uk member, once an account is deleted a red flag goes on the database and, while people cannot use the personal information, it stays on the system for a period of one year for administration purposes before being deleted automatically.
Where you contribute to 50connect.co.uk, Olderiswiser Media Limited will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted. For example, Olderiswiser Media Limited will only keep copies of entries to a photographic competition for the duration of the competition. However other areas (e.g. the Forum) are likely to have a longer, or even permanent, duration.
10. Can I find out what personal information Olderiswiser Media Limited holds about me?
Under the Data Protection Act you have the right to request a copy of the personal information Olderiswiser Media Limited holds about you and to have any inaccuracies corrected. We will use reasonable efforts to supply, correct or delete personal information about you on our files. You are required to provide 2 pieces of photographic identification and an administration charge may be incurred for the process.
Please address requests to the Data Protection Officer, 50connect.co.uk, Olderiswiser Media Limited, 16 Leigham Court Road, Streatham, London, SW16 2PJ
12. Cookies Policy – Information Olderiswiser Media Limited collects from you
a. What is a cookie?
A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer or mobile phone (referred to here as a “device”) browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. Many sites do this whenever a user visits their website in order to track online traffic flows.
Cookies record information about your online preferences and allow us to tailor the websites to your interests. Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these means that certain personalised services cannot then be provided to that user and accordingly you may not be able to take full advantage of all of 50connect.co.uk features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
Information supplied by cookies can help us to analyse the profile of our visitors and help us to provide you with a better user experience. For example: if on a previous visit you went to our education pages, we might find this out from your cookie and highlight educational information on your second and subsequent visits.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new subscriber||(a) Identity
|To deliver best website experience to you|
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
|Necessary for our legitimate interests to develop our products/services and grow our business|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established a privacy centre where you can make certain decisions about your personal data and request to see all personal data that we keep about you. We use the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Our marketing communications are delivered by a company called Infusionsoft. You can read about how we share data with Infusionsoft and how you can change your preferences here.
We will get your express opt-in consent before we share your personal data with any company outside 50connect and Olderiswiser Media Limited for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by visiting our newsletter preferences centre and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of registration on 50connect and will not inhibit your future use of the website.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Specific third parties listed in the table in [paragraph 4] above.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
International transfers –
We share your personal data within the Olderiswiser Media Limited Group and with Infusionsoft by Keap (Customer relationship management system). We use Infusionsoft by Keap to manage our email newsletter broadcasts and email marketing contacts list. This will involve transferring your data outside the European Economic Area (EEA).
Infusionsoft warrants that it will:
What solution does Keap offer for cross-border data transfers?
Under the GDPR, personal data may only be transferred outside the European Economic Area (commonly referred to as the EEA and which consists of the EU, plus Norway, Iceland, and Liechtenstein) in certain circumstances, such as to a country whose data protection laws are deemed “adequate” by the European Commission, or by relying on an approved data transfer mechanism.
Because Infusionsoft by Keap is based outside of the EU, it currently offers customers the EU Model Contract (the alternative to Privacy Shield, which comes from the EU and is provided by the FTC) to enable the lawful flow of personal data from the EEA to Keap in the United States.
The EU Model Contract contains standard contractual clauses which are approved by the European Commission, and which govern the lawful transfer of data from the EEA to countries outside of the EEA. Under the GDPR, additional legitimate methods of exporting personal data outside the EEA may be introduced. In the event of any changes to or new rules associated with the GDPR, Keap will review and respond appropriately.
What security controls has Keap implemented to safeguard my data?
Infusionsoft by Keap’s Data Security Statement goes beyond the customary confidentiality clauses found in the business terms of many SaaS providers. The statement describes some of the specific data security controls that are implemented and maintain a high standard of data security.
The Data Security Statement can be found here: https://keap.com/legal/data-security.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
[Details of retention periods for different aspects of your personal data are [available in our retention policy which you can request from us by contacting us OR set out in the table in paragraph 4 above].
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for [six] years after they cease being customers for [tax] purposes.]
In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
13. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. By visiting our Personal Information Request page you can:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Contact 50connect to request transfer of your personal data or ask specific questions about how your data is used.
- If you wish to exercise any of the rights set out above, please contact:
16 Leigham Court Road
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties
You personal details might be used by other websites in the Olderiswiser Media Limited Group [acting as joint controllers or processors] when you participate in a prize draw, a survey on 50connect. Your details are used only for the purpose of aggregating the entry data of prize draws that run concurrently across our websites and analysing the responses to surveys running concurrently across our websites. All Olderiswiser Media Limited websites are based in the UK.
External Third Parties
- Infusionsoft – provides a contact management platform that 50connect uses to registered member and newsletter subscriber data [details of how Infusionsoft holds this data can be seen in Point 6].
- Survey Monkey – is an online survey development cloud-based software as a service company. The company is compliant with EU/US Privacy Shield and GDPR laws. A copy of its privacy statement can be read here.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
This privacy notice was last amended 02 February 2020Last modified: June 10, 2021