Privacy Notice
H.Days Holdings Limited
Customer Privacy Notice
How we use your information notice
Happy Days Nurseries respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data that Happy Days Nurseries collects and uses about you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. You can request a pdf version of this policy from us using the contact details set out in this policy. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice. Happy Days Nurseries is the controller and responsible for this website.
1. IMPORTANT INFORMATION AND WHO WE ARE;
2. THE DATA WE COLLECT ABOUT YOU;
3. HOW IS YOUR PERSONAL DATA COLLECTED;
4. HOW WE USE YOUR PERSONAL DATA;
5. DISCLOSURES OF YOUR PERSONAL DATA;
6. INTERNATIONAL TRANSFERS;
7. DATA SECURITY;
8. DATA RETENTION;
9. YOUR LEGAL RIGHTS; and
10. GLOSSARY.
This privacy notice aims to give you information on how Happy Days Nurseries collects and processes your personal data, including any data you may provide through this website when you enrol a child with one of our nurseries or when you correspond with us. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This privacy notice supplements the other notices and is not intended to override them.
Happy Days Nurseries is made up of different legal entities, details of which can be found under section 10. (GLOSSARY). When you register a child for a place at one of our nurseries the relevant controller will be the company who runs that nursery and who is party to the contract with you. This privacy notice is issued on behalf of the Happy Days Nurseries so when we mention, “Happy Days”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Group responsible for processing your data.
We have appointed a Data Privacy Coordinator who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Coordinator using the details set out below.
Our full details are:
Happy Days Nurseries Support Centre
Chapel Town
Summercourt
Cornwall
TR8 5YA
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 19 May 2023. We may update this privacy notice from time to time. When we do so we will notify you of any significant changes by providing a notice on our website or by emailing you. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data or that of your child changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you (and potentially your child) which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, passport or another form of photo ID, marital status, title, NI number, date of birth, collection password, employer name, gender and relationship to child.
- Contact Data includes postal address, email address and telephone numbers.
- Child Data includes first name, last name, gender, date of birth, religion, ethnicity, first language, professional involvement or other safeguarding information, doctors details, next of kin, accident records, medical details (including allergy, dietary information and immunisations) and images of the child (as a record of their learning and promotional material).
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
- Technical Data includes browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with nursery services for your child). In this case, we may have to cancel our service you have with us but we will notify you if this is the case at the time.
- Direct interactions. You may give us your Identity, Contact, Financial and Child Data by filling in our Enrolment form or any other form or by corresponding with us by post, phone, and email or otherwise. Please note that if you give us details about someone else on the Enrolment form, it is your responsibility to make sure that they know that you are doing so and to give them a copy of this privacy policy.This includes personal data you provide when you:
- Contact us directly through our website;
- When you interact with us on social media;
- When you register/enrol your child at one of our nurseries;
- Request marketing to be sent to you;
- When you register to attend a Happy Days event; and
- When we contact you during our relationship with you.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
If another carer, or a co-parent, completes the Enrolment form for your child and fills in your contact details on your behalf, we will collect your personal data from them.
– Technical Data from the following parties:
a) analytics providers to carry out an analysis of our customers data and your interaction with our website.
b) Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
c) Occasionally we may receive personal information from other nursery providers, schools and or government departments or bodies. For example, where your child attends another nursery as well as Happy Days Nurseries.
- 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.
- Where we require your consent to process specific information about your child, such as health information.
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.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Types of data used:
Identity, Contact and Child data.
Lawful basis for processing:
We process this data where it is necessary to perform a contract with you. We also rely on consent where this relates to your child’s health data, information about racial or ethnic origin, or religious beliefs. We may also process this data where it is necessary for our legitimate interests, for example to ensure we have appropriate alternative contact details for carers if required.
Types of data used:
Identity, Contact and Child data.
Lawful basis for processing:
We process this data where it is necessary to perform a contract with you. We also rely on consent where this relates to your child’s health data, information about racial or ethnic origin, or religious beliefs. We may process this data to comply with our legal obligations, including safeguarding regulations. We may also rely on legitimate interests to ensure we have appropriate alternative contact details for carers in the event of an emergency.
This includes managing payments, fees and charges, and collecting or recovering money owed to us.
Types of data used:
Identity, Contact, Financial, Transaction, and Marketing and Communications data.
Lawful basis for processing:
We process this data where it is necessary to perform a contract with you. We may also rely on legitimate interests where necessary to recover debts due to us.
This includes notifying you about changes to our terms or privacy policy, and asking you to leave a review or complete a survey.
Types of data used:
Identity, Contact, Marketing and Communications, and Child data.
Lawful basis for processing:
We process this data where it is necessary to perform a contract with you, or where necessary to comply with a legal obligation. We may also rely on legitimate interests to keep our records updated and to understand how customers use our products and services. Where this relates to your child’s personal data, we rely on consent.
This includes administration and IT services, network security, fraud prevention, troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting of data, and activity connected with a business reorganisation or group restructuring exercise.
Types of data used:
Identity, Contact and Technical data.
Lawful basis for processing:
We process this data where it is necessary for our legitimate interests in running our business, maintaining our systems, and protecting our website and services. We may also process this data where necessary to comply with a legal obligation.
This includes measuring and understanding the effectiveness of the advertising we serve to you.
Types of data used:
Identity, Contact, Usage, Marketing and Communications, and Technical data.
Lawful basis for processing:
We process this data where it is necessary for our legitimate interests, including understanding how customers use our products and services, developing them, growing our business, and informing our marketing strategy.
This helps us improve our website, products, services, marketing, customer relationships and user experiences.
Types of data used:
Technical and Usage data.
Lawful basis for processing:
We process this data where it is necessary for our legitimate interests, including defining types of customers for our products and services, keeping our website updated and relevant, developing our business, and informing our marketing strategy.
This includes recommending goods or services that may be of interest to you.
Types of data used:
Identity, Contact, Technical and Usage data.
Lawful basis for processing:
We process this data where it is necessary for our legitimate interests, including developing our products and services and growing our business.
We may use your Identity, Contact, Technical and Usage 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 purchased services from us and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by contacting us at [email protected] any time.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please our Cookies Policy.
We will only use your personal data and that of your child 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 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 yours and your child’s personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- 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.
However, some of our external third parties are based outside the UK or the EEA so their processing of your personal data will involve a transfer of data outside the UK/EEA.
- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK government. For further details, see the UK’s list of adequate countries here.
- Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK. For further details, see the UK government’s information on alternative transfer mechanisms here.
We will only retain your personal data and that of your child 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 yours or your child’s personal data, the purposes for which we process yours and your child’s personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
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.
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.
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.
LAWFUL BASIS
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).
THIRD PARTIES
Internal third parties means any company within the Happy Day Nurseries group as defined in this glossary.
- If you choose to pay for our services using childcare vouchers or an equivalent means we will share the minimum amount of personal information with the scheme operator in order that they can make the necessary payments.
- If you child is entitled to Early Years Funding or an equivalent scheme we will share the minimum amount of personal information to the local council or government body in order that they can make the necessary payments.
- On occasion we may be required to provide personal information to schools, colleges and other educational institutions, government departments the police and/or another enforcement agency in respect of safeguarding.
- Service and financial providers acting as processors based in the EEA who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
YOUR LEGAL RIGHTS
You have the right to: