Right to Resist: BullyCam and VigilAuntie Privacy Policy

Introduction

We are Right to Resist UK Charity number 1201092 address East Deanraw, Langley on Tyne, Hexham NE47 5LY trading as “BullyCam” and “VigilAuntie” (referred to as “R2R” “we”, “us” “our” “VigilAuntie” or “BullyCam” throughout this privacy policy and you shall be referred to throughout as “you” or “your”).

We respect your privacy and we are committed to protecting your personal data. This privacy policy informs you about how we look after your personal data when you use our website www.BullyCam.org or our mobile application, regardless of where you visit it from, and tells you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

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

10. GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of this privacy policy

This privacy policy aims to give you information on how we collect and process your personal data through your use of our website, including any data you provide through www.BullyCam.org or our mobile applications BullyCam and VigilAuntie, when you log in and/or use our services (the "Services"). By using the Services, you acknowledge that you are accepting and consenting to the practices described in this policy.

[Our Services are not intended for children and we do not knowingly collect data relating to children.]

It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements the other policies and is not intended to override them.

Data Controller

R2R is the data controller and responsible for your personal data and the Services. We are regulated under the General Data Protection Regulation which applies across the European Union and the United Kingdom.

We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Right to Resist UK Charity number 1201092 address East Deanraw, Langley on Tyne, Hexham NE47 5LY

Name or title of data protection officer: Charles Yeadon

General email address: contact@righttoresist.org

Postal address: East Deanraw, Langley on Tyne, Hexham NE47 5LY

We hope that we can resolve any query or concern you raise about our use of your information. However, under the UK General Data Protection Regulation you have the right to make a complaint at any time with the relevant supervisory authority. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone 0303 123 1113.

Changes to the privacy policy and your duty to inform us of changes

This version was last updated on 29/04/2025, phone number, email address. We will provide you with reasonable prior notice of substantial changes in how we use your information, including by email at the email address you provide.

If you would like this policy in another format (for example: audio, large print, braille) please contact us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

The Services 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 Services, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

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 and process different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, phone number, email address image

• Contact Data includes postal address, email address and telephone numbers.

• Technical Data includes internet protocol (IP) address, your login data, 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.

• Profile Data includes your username and encrypted password, feedback and survey responses, requests you have made via our website, telephone or by post.

• Usage Data includes information about how you use our Services (website and mobile application).

• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical, learning achievement 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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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 our Services).

How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your data by filling in forms on our website or our mobile application or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

1. create an account to use our Services;

2. use the Services;

3. request information or marketing to be sent to you;

4. complete a survey; or

5. give us some feedback.

• Automated technologies or interactions. As you interact with our Services, we may automatically collect Technical Data about your equipment, usage and patterns. We collect this personal data by using cookies, server logs and other similar technologies.

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

1. Technical Data from the following parties:

• analytics providers such as Google based outside the EU; and

• advertising networks such as HubSpot, Facebook, Twitter, and Instagram.

2. Identity and Contact Data from BullyCam or VigilAuntie (what3words) and publicly available sources such as Companies House, the Electoral Register based inside the EU.

3. HOW WE USE YOUR PERSONAL DATA

We will only process information collected from you in a fair and lawful manner. 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 (i.e. when you sign up to use our Services).

• 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 in the below table 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

To register you as a new user and enable to use our Services

To manage our relationship with you which will include:

Notifying you about changes to our terms or privacy policy
Asking you to leave a review or
take a survey

To administer and protect our Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data

1. Identity 2. Contact 3. Profile

1. Identity 2. Contact 3. Profile 4.

1. Identity 2. Contact 3. Technical

Lawful basis for processing interest

1. Performance of a con you with our Service

Performance of a con
Necessary to comply
Necessary for our leg
records updated and
Services, to develop
Consent (with respe

Necessary for our leg our business, provis services, network se the context of a bus restructuring exercis
Necessary to comply
g
e inform our marketing

To deliver relevant content and

Marketing and

Communications

1. Identity

advertisements to you and measure or

2. Contact

1. Necessary for our le

understand the effectiveness of the

3. Profile

users use our Servic

advertising we serve to you

4. Usage

Purpose/Activity

Type of data

Lawful basis for processing interest

To use data analytics to improve our Services, marketing, user experience

To make suggestions and recommendations to you about goods or services that may be of interest to you

To share content with third parties where necessary i.e. the police or other law enforcement body or if required in legal proceedings

1. Identity
2. Contact
3. Technical 1. 4. Usage
5. Profile

1. Identity 1. 2. Profile 2. 3. Contact 3.

1. Technical 2. Usage

Necessary for our leg types of users for ou website/mobile appl develop our Services strategy)

Necessary for our leg our Services)

Necessary for your v Necessary to perform Necessary to comply

We strive to provide you with choices regarding certain personal data uses, particularly around

5. Marketing and

Communications

6. Technical

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Marketing

You will receive marketing communications from us if you have requested information from us or are using our Services or if you provided us with your details via our website contact us page, in each case as it applies to any electronic marketing, you have consented to our contacting you for the stated

marketing purposes. For other forms of marketing, e.g. post or telephone, we will contact you only if such communication would fall within our legitimate interests.

Third-party marketing

We will not share your personal data with any third party company for their marketing purposes. Opting out

You can ask us to stop sending you marketing messages at any time by following the opt out/unsubscribe 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 a signing up to use our Services, warranty registration, or service experience.

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 our website or mobile application may become inaccessible or not function properly. For more information about the cookies we use, please see our COOKIE POLICY.

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.

4. 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 3 above.

• 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. 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 policy.

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.

5. INTERNATIONAL TRANSFERS

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Note that:

• Google and [ ] our analytics providers, are based outside of the EEA; and

• our advertising networks such as Facebook, Twitter and Instagram are based both inside and outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. 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.

7. DATA RETENTION

Retaining personal data

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.

In some circumstances you can ask us to delete your data: see 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 as it will constitute personal data.

We may retain data from back-ups for up to 365 days, this is “Archived Data”. Archived data is stored in a “non-live” state, with the sole purpose to protect against loss and damage of User Data. A full database backup is conducted every night and prior to making updates to the Services. After the 365 day period Archived Data will be deleted permanently and will not be able to be restored.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access

• Request correction

• Request erasure

• Object to processing of your personal dara

• Request restriction of processing your personal data

• Request transfer of your personal data

• Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.

If you would like to unsubscribe from any of our electronic marketing communications to you, you can also click on the ‘unsubscribe’ button at the bottom of such communication. It may take up to 28 days for this to take place.

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.

9. GOVERNING LAW AND JURISDICTION

1. This agreement and any dispute or claim arising out of or in connection with it or its subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of England and Wales.

2. The courts of England shall have exclusive jurisdiction to settle any such dispute or claims relating to these terms and conditions.

10. GLOSSARY

Lawful basis

1. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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.

2. 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.

3. 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. 4. Public task means the processing is necessary to perform a task in the public interest or for official functions, and the task or function has a clear basis in law.

5. Protecting the vital interests of the data subject or another natural person means that processing is necessary to protect someone’s life.

6. Consent means we have your express consent to process your personal data for the stated purposes.

Third parties

External Third Parties

• Service providers acting as processors who provide system infrastructure, data storage, IT and system administration services, including AWS, Google.

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK 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.

• The police or other law enforcement bodies as applicable worldwide.

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.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.