Privacy Policy
The Formation respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, and protect information about you when you use our website, become a member of our community, or otherwise interact with us.
This Policy is issued by The Formation Club Limited, a company registered in England and Wales under company number 17296030, whose registered address is at Venture, Warren Lane, Cross in Hand, East Sussex, TN21 0TB, trading as The Formation ("we", "us", "our"). We act as the data controller responsible for your personal data.
1. Information We Collect
Information You Give Us
When you sign up as a Formation member, register for an event, or contact us, and depending on how you interact with us, you may provide:
- Your name (first and last)
- Your email address
- Your city or country of residence
- Your postal address, where you have purchased a product or asked us to send you something
- Your social media handles
- Your gender
- Your date of birth, or your year of birth where we only need to confirm you are 18+ and to personalise your experience
- Other information you choose to share, including: your mobile number if you join our group message community; your professional background; any content you choose to send us (including photographs, video, audio, interviews, written recommendations and guides), and any information you volunteer in that content; your membership type and status; the events you have attended or registered for; and how you interact with our emails, website and forms
Information We Collect Automatically
We use cookies and similar technologies on our website. Cookies that are strictly necessary for the site to function are set automatically. All other cookies (including analytics and advertising cookies) are only set where you have given your consent through our cookie banner. When you visit our website, we may automatically collect limited technical information including your IP address, browser type, device information, and pages visited. You can change your cookie preferences at any time. See our Cookie Policy for full detail.
2. How We Use Your Information and Our Legal Basis
Under UK GDPR we must have a legal basis for everything we do with your personal data. The list below sets out the basis we rely on in each case and what we use your information for.
Legitimate Interest
- Keeping our community safe, enforcing our community standards, and preventing fraud and misuse
- Grouping members by interests, engagement, location or membership type so that our communications are relevant to you
- Measuring how our emails, campaigns and website perform
- Reporting to our partners and sponsors on community and campaign performance, in aggregated and anonymised form
- Retaining published content and campaign materials in our archive for record-keeping and portfolio purposes
- Improving our website and member experience
- Establishing, exercising or defending legal claims
Performance of a Contract With You
- Managing your membership, verifying eligibility for our group message community and other member benefits, and responding to your enquiries
- Processing payments and administering paid memberships and ticket purchases
Consent
- Sending you our newsletter, The Formation Dispatch, and notifying you about Formation Experiences, events and membership opportunities
- Telling you about our partners' and sponsors' offers, competitions, events and products, sent by us
- Sharing your contact details directly with a named partner or sponsor so that they can contact you
- Featuring content you have sent us across our marketing channels, including our social media, website, newsletter and CRM
- Featuring you personally, including as a Formation Spotlight, using your name, likeness, voice, social media handle, biographical details and words
- Showing you Formation content on social media and advertising platforms, including by uploading a securely hashed version of your email address to those platforms
Explicit Consent (Article 9(2)(a) UK GDPR)
Publishing information about your racial or ethnic origin, health, religious or philosophical beliefs, sexual orientation, political opinions or trade union membership, where you choose to share it as part of a feature or interview. We will always ask for this separately and will not publish such information without your consent.
Compliance With Legal Obligations
Meeting our legal, accounting and regulatory obligations.
Permissions to use your content. Separately from data protection law, where you send us photographs, video, audio, interviews, recommendations, or other material, you grant us a licence to use it under an instrument fit for purpose. That licence is a matter of copyright and contract law. It is not a legal basis for processing your personal data (for that, we rely on the bases set out above).
3. Who We Share Your Data With
We do not sell your personal data. We share limited data only with trusted service providers who help us operate.
Providers Acting on Our Instructions
- Klaviyo (email service provider and CRM) - for sending newsletters and event communications
- Ticket Tailor (event ticketing platform) - when you register for Formation Experiences
- Airtable (CRM service)
- Google Workspace (Formation team operations and workflows)
- And other hosting and analytics providers
Organisations That Act Independently
The following organisations determine how they use your data themselves, and process it under their own privacy policies. We recommend you read them.
- Stripe - where you make a payment, e.g. if you become a paying Formation Club member or order merchandise
- Social Media Platforms - where we publish content on social media, the platform operates as an independent data controller and processes information about you under its own terms and privacy policy. We do not control what a platform does with that information, and we cannot control what other users do with content once it is public. All content published may be copied, shared, downloaded or retained by people we have no relationship with.
- WhatsApp - where you join our race-weekend group message community. Please note that when you join a group, your mobile number and profile name are visible to other members of that group. We cannot control what other members do with that information.
Hosting and analytics providers that help us run the website. All providers are bound by data processing agreements and may only use your data on our instructions.
Partners and sponsors. Where you have specifically asked us to pass your details to them or entered their competition or event, we will always tell you who they are before you decide. Once they hold your information, they are responsible for it under their own privacy policy. We may also share information with sponsors and event partners in aggregated, anonymised form (for example, "65% of our community is based in the UK"). We will never share your individual personal data with sponsors or third parties for their own marketing without your explicit and informed consent.
We may also disclose your data where we are required to do so by law, or to establish, exercise or defend legal claims.
4. International Data Transfers
Some of our service providers may store data outside the UK or European Economic Area, including in the United States. Where this happens, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved under UK GDPR.
5. How Long We Keep Your Data
We keep your data only for as long as necessary. Examples of retention periods include:
| Record | Indicative retention |
|---|---|
| Membership and transaction records | Membership term + 6 years, subject to legal and accounting needs |
| Marketing consent and suppression | While active; until you unsubscribe or withdraw consent, after which we retain only what is necessary to honour your opt-out |
| Unsuccessful applications / general enquiries | 24 months |
| Community moderation records | Duration of membership + up to 3 years; longer for serious incidents/claims |
| Event attendance and incident records | 3 years; up to 6 years or longer for claims/safeguarding |
| Content (e.g. photos/video) | For the stated campaign period, reviewed periodically; or for archive purposes for 5 years, but will not be re-used in marketing after you have asked us to stop |
| Cookie/analytics data | According to the consent tool and provider settings |
| Accessibility/health information | Deleted or anonymised as soon as no longer needed |
6. Your Rights
Under UK GDPR, you have the right to:
- Access - request and access a copy of the data we hold about you
- Rectification - correct inaccurate or incomplete data
- Erasure - request deletion of your data (the "right to be forgotten")
- Restriction - restrict our processing of your data
- Object - object to our processing of your data
- Portability - request data portability
- Withdraw consent - at any time, by using the unsubscribe link in any email, updating your preferences on our website, or emailing us. Withdrawing consent does not affect the lawfulness of anything we did before you withdrew it. If you ask us to stop using content that features you, we will stop using it in new communications and remove it from channels we control. We cannot always retrieve material that has already been printed, sent out by email, published by a partner, shared or saved by other people, or embedded on a third-party platform. Where that is the case, we will not use it again.
Some of these rights are qualified and do not apply in every situation. For example, we may not be able to delete data we are required to keep by law. If we cannot act on a request, we will explain why.
Your right to object to marketing. You have an absolute right to object to us using your personal data for direct marketing, including profiling related to direct marketing. If you tell us to stop, we will stop. You can do this at any time using the unsubscribe link in any email, on our website, or by emailing hello@wearetheformation.com.
Making a request or a complaint. To exercise any of these rights, contact us at hello@wearetheformation.com. You also have the right to complain to the Information Commissioner's Office at ico.org.uk - we would always rather hear from you first so that we can put things right.
7. Security
We use appropriate technical and organisational measures to protect your personal data. However, no system is completely secure, and we cannot guarantee the security of data transmitted over the internet.
8. Children
The Formation is intended for adults aged 18 and over. We do not knowingly collect personal data from anyone under 18 years old. If you believe a minor has provided us with personal data, please contact us and we will delete it.
9. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above. Material changes will be communicated to members by email.
10. Contact Us
If you have questions about this Privacy Policy or how we handle your data, please contact:
The Formation Club Limited
Email: hello@wearetheformation.com
Venture, Warren Lane, Cross in Hand, East Sussex, TN21 0TB