Girls' Brigade Northern Ireland, GBNI

Privacy Notice

What is personal data?

Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by the General Data Protection Regulation (the “GDPR”).

What are your rights?

  • The right to be informed - to be provided with clear and concise information about what we do with your personal data.
  • The right of access – to request a copy of your personal data.
  • The right to rectification – to allow you to have inaccurate personal data rectified or incom¬plete personal data completed.
  • The right to erasure - to have your personal data erased at any time. This is also known as the ‘right to be forgotten’.
  • The right to restrict processing – to have the freedom to restrict the processing of your personal data in certain circumstances that limits the way that we use your data.
  • The right to data portability - to view the personal data you have provided to a controller in a structured, commonly used and machine readable format. It also gives you the right to request that a controller transmits this data directly to another controller.
  • The right to object - to ask us to stop processing your personal data.
  • Rights related to automated decision-making and profiling - to protect your rights if we carry out solely automated decision-making that has legal or similarly significant effects on you.
  • You have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

Who are we?

GBNI is registered with the Information Commissioner’s Office as ‘The Girls’ Brigade Northern Ireland Ltd’. This privacy notice outlines how we decide how the personal data you provide to us is processed and for what purposes it is used. GBNI, as the data controller, will take care to preserve, respect and protect your privacy. We do not process personal data unless it is expressly provided to us voluntarily. We do not share, sell, or otherwise provide personal data to third party organisations in any way.

GBNI may change this Privacy Notice from time to time by updating it on the GBNI website. You should check the website periodically to ensure that you agree with any changes.

How do we process your personal data?

We comply with our obligations under the “GDPR” by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

  • To administer membership records;
  • To manage our volunteers (including AccessNI applications);
  • To provide medical assistance, if needed;
  • To provide our membership with training opportunities;
  • To develop and provide age appropriate programme resources;
  • To provide a range of suitable competitions;
  • To administer a number of Award Schemes;
  • To promote the values and interests of the organisation;
  • To maintain accurate accounts and records; and
  • To inform you of upcoming news, events, activities and services

What is the legal basis for processing your personal data?

GBNI primarily relies on the following legal bases for processing particular data:

  • Legitimate Interest – For the processing of members details for GB business purposes regarding programmes, resources, training, regulations and general management of the organisation, across Company, District and National levels. For the processing of registered customers details to allow us to provide the best possible service to our customers with the goods and services they require.
  • Legal Obligation – Under the law we must hold accurate account records for the purposes of HMRC and other funding bodies.
  • Consent – We annually review the consent given by our membership so that we hold up-to-date records to assist with the management and administration of the organisation, across Company, District and National levels.

Collection and use of personal information

AT COMPANY LEVEL

The local church where the GB company operates, acts as the data controller for the processing of personal data at company level. Captains and leaders of the GB company, act as the data processors and must follow the church’s guidelines and policies when processing personal data on the church’s behalf.

When the GB company is off-site from the local church and is carrying out activities under the authority of GBNI, then GBNI acts as the data controller for the processing of personal data. Such as outings, camps and attending GBNI events either at district or at national level. District Office Bearers act as the data processor and must follow GBNI guidelines and policies when processing personal data on the districts behalf.

How do GB companies use your data?

Personal data is provided to the GB company on a voluntary basis through parental consent (namely, a parent/carer/legal guardian express agreement). A GB member aged 13 or over is considered capable of giving consent themselves and will not require express agreement from a parent/carer/legal guardian.

The Annual Parental Consent Form asks for name, address, date of birth, GP name and contact details, medical information and treatment, emergency contact details for two people, intimate care consent, communication/IT consent for older girls and recognition of our child protection policy. GB companies will use this information only for the administration and management of their GB company. GB companies are not permitted to use any of this information for any other purpose than what the form intends.

When a GB member attends an activity outside of the church premises, they are required to submit a completed Consent for Trips/Outings/Camps Form to the leader in charge prior to the activity.

The Consent for Trips/Activities/Camps Form asks for name, address, date of birth, GP name and contact details, medical information and treatment and emergency contact details for two people. GB companies will use this information only for the administration required for the named activity on the form. GB companies are not permitted to use any of this information for any other purpose than what the form intends. The Leader in charge of the company brings the forms to the activity and keeps them with her at all times. GBNI/District Personnel should never come into contact with this personal data, other than for health and safety reporting or child protection reporting.

Due to the historical nature of GB and the desire to keep photos and video recordings, GBNI has re-evaluated how it collects photo consent across all areas of GBNI. Please refer to the ‘Use of photographs, videos and sound recordings’ section of this document for full details.

How long is data stored for?

GB companies will only keep personal data for as long as necessary to fulfil the purposes on which they collected it (eg. annual registration) and including for the purposes of satisfying any legal, accounting, or reporting requirements.

GB companies are not permitted to store personal data forever; they only hold GB members and family data for as long as they are legally able to do so. However, sometimes they will keep personal information for historical reasons (eg. photographs, badge and attendance records) but you will always have a right to ask for it to be destroyed.

In determining the appropriate retention period for personal data, we require our GB companies to 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 they process your personal data and whether they can achieve those purposes through other means, and the applicable legal requirements.

How is data secured?

Each GB company must put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

GB companies may occasionally have to share some data regarding GB members’ with service providers such as:

  • Girls’ Brigade Headquarters (eg. registration to GBNI level activities, health and safety reporting, child protection reporting and use of photographs)
  • A new GB company; if a member wishes to transfer • District Office Bearers
  • The Duke of Edinburgh’s Award Office
  • Designated Church Officers for Health and Safety and Child Protection
  • Safeguarding Trusts
  • PSNI
  • Department of Education for funding purposes

GB companies are not permitted to share your personal data to any third parties organisations.

AT DISTRICT LEVEL

GBNI acts as the data controller for the processing of personal data at District Level. District Office Bearers acts as the data processor and must follow GBNI guidelines and policies when processing personal data on the districts behalf.

How district personnel use your data?

If working alongside the District as a District Executive Member, Office Bearer, GBNI Team Representative, GEMS Representative, Prayer Co-ordinator and Brigade Council Representative; you will be required to give voluntary consent to receive communication regarding your district and any arrangements for the forthcoming GB session.

The District Personnel Data Consent Form asks for name, address, contact telephone numbers including mobile, email address and consent to be contacted regarding GB business. District personnel will use this information only for the administration and management of the district. District personnel are not permitted to use any of this information for any other purpose than what the form intends.

You are free to share only the information you wish to on the form and you are free to request for your consent to be updated or removed at any time. Please contact the District Secretary if you would like to withdraw any consent you have given. Please note: Your data will be shared with GBNI and you must notify GBNI Headquarters of any changes to this data.

How long is data stored for?

District personnel will only keep personal data for as long as necessary to fulfil the purposes on which they collected it (eg. annual registration) and including for the purposes of satisfying any legal, accounting, or reporting requirements.

Districts are not permitted to store personal data forever; they only hold GB members data for as long as they are legally able to do so. However, sometimes they will keep personal data for historical reasons (eg. photographs and minutes of meetings) but you will always have a right to ask for it to be destroyed.

In determining the appropriate retention period for personal data, we require our District personnel to 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 they process your personal data and whether they can achieve those purposes through other means, and the applicable legal requirements.

How is data secured?

Each District must put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

Districts may occasionally have to share some information regarding GB members’ with service providers such as:

  • District personnel; when supervising events may require to be notified of any medical requirements
  • Girls’ Brigade Headquarters/Designated Officers (eg. health and safety reporting, child protection reporting and use of photographs)
  • District Office Bearers
  • The Duke of Edinburgh’s Award Office
  • Safeguarding Trusts
  • PSNI

District Personnel are not permitted to share your personal information to any third parties organisations/suppliers.

GBNI has put in place procedures to deal with any suspected data security breach and if you are subject to a suspected data breach, you will be notified and along with the Information Commissioner’s Office where we are legally required to do so.

AT NATIONAL LEVEL

At this level we provide a vast range of services that capture and process some form of personal data. Each service is listed giving details what we use, why we use it, how it is stored and disposed of.

General Public

GBNI does not store or capture any personal information on users with general public access. However, when you visit and navigate around our website we collect statistical information relating to site usage through Google Analytics. This information does not include any personally identifiable information.

There are a number of areas within the site, which may ask for some personal data to allow access to use those areas of the site. The data collected will be held for the sole purpose of GBNI and will not be distributed to any third party organisations.

Our “Contact Us” and “Feedback” pages, ask for your name, email address and phone number. These details are then sent to either info@gbni.co.uk or nationalsecretary@gbni.co.uk for the recipient to respond to your request. Once actioned the email will be deleted or maybe stored on file if GBNI deem it necessary.

>h4>Online shop

GBNI ask all customers to register with our online shop. We collect and store the following information - name, billing address, postal address, email, telephone number, GB Company and order history. You can log into your account at any time and update your details. We use this information to fulfil orders, follow up order queries, manage stock and email customers with shop notices regarding extra openings or closures. We use both Royal Mail and DPD Courier Services to dispatch our orders. We do not share personal data with Royal Mail as we operate a franking service on-site for all orders under £4.60 in postage charges. For larger orders being sent through our DPD Courier service, we input the customer’s name, postal address, order number and email address into the DPD CDS Shipping Solutions Application which is on an encrypted PC. If you do not wish to use the courier service, you may collect your order in store or contact customerservices@gbni.co.uk to arrange payment of any additional postage charges applied by Royal Mail for larger orders.

Leaders' Section

Leaders of GBNI affiliated companies are asked to register to use a leaders only part of the site for access to resources, paperwork and other promotional materials for viewing and download. We collect and store their name, email address and GB company name for this purpose. GBNI only requires the requested personal information to ensure those applying for access to this area are registered leaders on the GBNI web-filing database. You can delete your account at any point by contacting info@gbni.co.uk

Online Booking

Leaders of GBNI affiliated companies may use our online booking system to book training courses and other events. We collect and store the name, company name, district number, email address telephone number and other requirements eg. dietary or access. This information is used to fulfil the booking. The information may be placed onto an excel register and used for the purpose of the activity. This data is stored on an external secure server and will be deleted after the event. All paper registers if containing personal data will be destroyed after the event. Reminder emails/texts may be sent to the participant prior to the event. GBNI uses a secure text messaging service for the purpose of sending bulk texts.

Web-filing Database

The data collected in this area is held for the sole purpose of GBNI and will not be distributed to any third party organisations. GBNI only requires the requested personal information for all current registered leaders for insurance purposes and making contact for any GBNI related business. The database is a web-based service hosted on a secure external server and is maintained by our web support company Flint Studios. The database has a separate log in feature that can only be accessed by approved users and is directly managed by GBHQ administration staff.

  • Company – Only your Captain or Correspondent can access and amend the data held under the named company.
  • District – Only the District Secretary can access the contact details of the leaders in her District. She cannot amend any of the personal data.
  • HQ – Only GBHQ staff have access to this area which give full access to all areas for all companies and leaders data. Staff can amend all details and generate reports that are useful for the management of administration for the organisation.

All current leaders must complete a Leader Annual Consent Form giving clear consent to share their personal information with GBNI. We ask for name, address, contact numbers, email, date of birth and general information regarding the leaders rank, training, AccessNI and contact consent approvals. A leader can ask their Captain/Correspondent to update or remove their details at any point or alternatively they can contact info@gbni.co.uk to make the requested changes.

The Captain/Correspondent can opt into our GBNI email address that can be allocated to each GB company to increase online security.

Our web-filing also links appointed leaders to their District and Executive roles. District roles are outlined in the District Booklets provided to GBHQ in June of each year by each District. GBNI Executive roles are appointed through the election process carried out by Brigade Council. Each leader holding a role at either level must complete a Personal Data Declaration Form to confirm how GBNI are allowed to use your personal data for this role.

All details for resigning leaders on the web-filing database associated to the named GB Company must be removed annually by their Company Captain/Correspondent. Please note that our online web-filing system does not retain an archive system and is stored on a secure external server. Manual returns will be kept securely on file at GBHQ for a period of two years after which point these returns will be destroyed.

GBNI is part funded by external bodies who may ask us to provide them with information relating to the work we do and at times we may be required to pass on statistical information provided on the paper/electronic Annual Return regarding our membership and activities that are funded by them.

Bulk Text Messaging Service

  • GB Captains/Correspondents/Chaplains/Officer Bearers – for general reminders of deadlines and upcoming news, events and training in GBNI.
  • Leaders with confirmed bookings – to provide updates and reminders to attend courses, events, competitions and trainings with GBNI.
  • Team Representatives – for reminders of team meetings and general communication.

GBNI sends all bulk messages through a secure text messaging service. GEMS and Prayer Coordinators communicate through a WhatsApp group that is managed by GBNI. Districts may operate their own WhatsApp or alternative system to communicate amongst its executive members. Recipients can opt out of this service at any point by contacting GBHQ via info@gbni.co.uk

GBNI Newsletter

The GBNI Newsletter is distributed by post up to five times a year to Chaplains/Captains/ Commissioned Officers. Chaplains/Captains/Commissioned Officers must complete the Leader Annual Consent Form and indicated clear permission for their name to be added to the distribution list. Once consent is given, the Captain/Correspondent must update the web-filing system to indicate the leader’s preference to either opt in or opt out from this service. Address details are shared with a third party postal company for the sole purpose of distributing the newsletter to leaders. Data will be sent via a secure encrypted file and the postal company must destroy all files once the newsletter has been distributed. Third party postal companies, must confirm at the time of quotation that their retention policies are in line with GDPR to ensure appropriate data safeguards. They will only process personal information on our instructions and they are subject to a duty of confidentiality. Leaders may choose to opt out at any point by contacting GBHQ via info@gbni.co.uk

eNews

Leaders of GBNI affiliated companies are invited to subscribe to our eNews through our Leaders’ Section. Leaders will not be automatically added to this service, they must give explicit consent by manually opting-in via a link on the Leaders’ Section. We only collect and store your name, GB Company and email address. We use this information to deliver the GB eNews via email. GBNI eNews is issued through a secure password protected email facility via Constant Contact. You can unsubscribe from this service at any point by selecting the unsubscribe button at the bottom of your last eNews received or by emailing info@gbni.co.uk

eDofE

GBNI is an operating authority for The Duke of Edinburgh’s Award. Registered participants that log into the eDofE system via www.dofe.org are advised to read over the DofE privacy policy and understand how they store and use data. GBNI personnel are able to access and manage certain areas of the eDofE system regarding our members and centres that are involved in The Duke of Edinburgh’s Award scheme. The information gathered is requested by the DofE Office for administration and management purposes. GBNI only uses this information for its involvement in registration, administration and completing the award for its members. At no point is information used for another GBNI business. Paper registrations are returned to the associated GB company. GBNI only holds paper requests for attending the presentation service which are stored securely and are then disposed of, after the event.

Research surveys

When completing online research surveys for GBNI, most surveys will be anonymous. However depending on the nature of the research to be carried, GBNI from time to time ask for your name, associated GB company and email address. Surveys are currently completed via a secure external online survey company called Survey Monkey which is password protected. The data collected through these surveys will be used for research analysis for GBNI only.

Use of photographs, videos and sound recordings

Due to the historical nature of GB and the desire to keep photos and video recordings, GBNI has re-evaluated how it collects photo consent across all areas of GBNI. Going forward, photo/video consent will be collected on a separate form which only gathers the necessary data for securing consent to take, keep and use photos and videos. This gives more security and freedom for companies to dispose of annual consent forms without destroying photo consent for images that are held by the company or by GBNI. GB companies will be required to review and update photo consent annually for the purposes of taking photos/videos at company level activities.

GBNI may take photographs, videos and sound recordings at its events for use in printed and electronic media for promotional purposes. For GBNI level activities, GB companies will be required to seek photo/video consent prior to each activity by asking parents to complete a ‘Photo Consent for GBNI Activities Form’ this use to be included in the ‘Consent for Outings/Activities/Camps Form’. The GB company should hold the original form to cover any photos they may take at the GBNI activity, however they must present a copy of the form for each child to GBNI personnel at each GBNI event prior to its commencement. This is to safeguard the consent of the photo and how GBNI may use it. No photo is permitted of any child without written consent from a parent, carer or legal guardian. Leaders are not permitted to sign consent for a parent, carer or legal guardian behalf.

All participants and spectators will be informed of this privacy policy prior to recording and you are free to indicate to the organisers if you do not consent for you to be in such images or recordings. Depending on the activity, you may be asked to step out from the shot.

All photo consent collected at GBNI activities is held securely at GB headquarters for our records and will be disposed of when the photo is no longer being used for GBNI purposes. All images are archived on a secure external server and may be used for research, publication, press releases, education, displays and exhibitions. Images and recordings will not be distributed to any third party organisations with exception to sending a press release to local newspapers (you will be informed of this prior to the commencement of the event). Some images or recordings may be selected for permanent preservation in GBNI’s history room for historical purposes and may be used for publication, education, displays and exhibitions.

CCTV

GBNI operates CCTV cameras on site at its Headquarters for access and security purposes. Images are recorded on a hard drive that is stored securely and encrypted. Signage is well displayed across the premises to inform, staff, visitors and customers.

Protection of Financial Information

It is only natural to have concerns around entering sensitive personal or credit card details. GBNI would like to assure you that all purchases made on the GBNI site for online booking or via the online shop are processed off site by our merchant services partner Realex Services or SagePay. We do not collect or store any financial information. When completing a purchase users are temporarily transferred to Realex/Sagepay secure websites to input payment details to complete the purchase. When issuing refunds, GBNI log into a secure area on the Realex/SagePay website to action the refund. At no point are bank account details visible to GBNI. If we do have to take a manual booking/order over the phone, the booking/order will be processed at that point and any data noted will be destroyed immediately. Any person found to be using credit cards fraudulently on this website will be prosecuted. All financial records are kept for a period of seven years and are then securely disposed of.

How we use your data?

GBNI use your information to provide the service that you have opted in to, such as our Newsletter, eNews, Leaders’ Section access, online booking and online shop orders. We do not pass your personal information to any other third party organisation unless we are required by law to do so. We do not under any circumstances rent, sell or otherwise provide your data to third party organisations for their marketing purposes. Nor do we provided members of the public with contact details for leaders without prior consent as indicated in the Company Annual Return for the current session. GBNI does not hold personal data for children centrally; this information is held securely at company level with exception to documents needed for issues regarding child protection, health and safety and security. We only hold information for as long as it is necessary for the management and administration purposes of the organisation. Once data is deemed no longer necessary, it shall be securely disposed of.

Google Analytic cookies: GBNI use Google Analytics, a web analytics service provided by Google Inc. Google uses cookies to collect and analyse information about how the website is used. Google undertakes not to associate your IP address with other data held by Google. The data cannot be used to identify any individual but allows us to analyse how to improve our site and deliver a better service. If you do not wish to accept cookies you can de-activate the appropriate settings on your browser.

This information is collected from your computer regardless of whether or not you register with us and is not personal to you. This includes the following:

  • Operating system (eg. Microsoft Windows 7 or IOS);
  • Browser software (eg. Google Chrome or Safari);
  • Your IP address (the unique Internet network address of your machine);
  • Your geographic location;
  • Access times (the time spent on the GBNI website);
  • Referring domain (the website you were browsing prior to your visit to the GBNI website);
  • The device you are using to visit the site (eg. mobile, PC or tablet); and
  • The click through rate (the number of pages entered whilst visiting our website).

How is data secured?

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate technical measures to safeguard and secure the information we process; to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Any personal data that we do collect is stored on our secure GBNI server based at our headquarters in NI and on the secure external server provided by our web support company. We use the latest firewall and security technology to ensure the integrity and safety of all information that we store. We do not transfer any data outside of the UK for any reason. All staff complete an induction process at the point of employment and are supplied with a copy of our latest Data Protection Policy and associated policies. All current staff have completed data protection training and are trained how to securely use our internal systems that hold personal data.

GBNI may occasionally have to share some information regarding GB members with service providers such as:

  • GBNI personnel when supervising events may require to be notified of any medical requirements
  • Designated Officers (eg. health and safety reporting, child protection reporting and use of photographs)
  • District Office Bearers
  • GBNI Executive Officer Bearers
  • The Duke of Edinburgh’s Award Office
  • IT communications company
  • Website support company
  • Postal service companies
  • Realex/Sagepay
  • Safeguarding Trusts
  • PSNI

GBNI has put in place procedures to deal with any suspected data security breach and if you are subject to a suspected data breach, you will be notified and along with the Information Commissioner’s Office where we are legally required to do so.

Access to Information

Everyone has the right to withhold or restrict any of their information and can amend information if it changes. Everyone has the ‘right to be forgotten’ and can send a request into GBNI to check what details has been stored about them and for their details to be deleted from our records. However, due to any potential child protection, health and safety or security issues, information may need to be retained for a period of 30 years, if GBNI deems this necessary. To make a Subject Access Request, please call GB Headquarters on 028 9454 8054, press 2 for the office or alternatively email us via info@gbni.co.uk. Please allow 30 days for this information to be provided.

Copyright and Trademark Information

Except where stated to the contrary, the material on this site is Copyright 2012, The Girls' Brigade, Northern Ireland - all rights reserved. Material on this site may be downloaded or printed for private use by leaders in GBNI affiliated companies for use within their own company provided that the source (GBNI) is acknowledged. The GBNI logos may not be copied from this site for any use. GBNI affiliated companies may use the GB logos under certain circumstances - full details may be found on the logo page within Leaders’ Section on this site.

Disclaimer

It is important to note, that this is not an exhaustive list and there may be other areas where data is collected for administration purposes of the organisation. We aim to keep this privacy notice up-to-date and as accurate as possible.

Every effort is made to ensure accuracy. All information on this site has been placed here in good faith. We do not intend:

  • To break the law of the UK or any other applicable country;
  • To cause harm to any person through the information included;
  • To infringe the copyright of any person; or
  • To cause offence to others, particularly racial or sexual offence.

This privacy notice only applies to the GBNI’s collection of information. If you follow a link from the GBNI website to any third party websites; please ensure you familiarise yourself with their privacy notice before sharing your personal information as it will not be covered by our privacy notice. If you feel that any part of our services breaches these rules, please contact at first instance, info@gbni.co.uk, and subsequently the GBNI National Secretary (nationalsecretary@gbni.co.uk) or at the postal address given below.

Report a breach in data protection

Everyone is responsible for safe management of personal data within your GB company. Therefore, it is vital that all leaders are aware of the data protection policies and procedures and how to report a data breach. The reporting procedures will depend on where the data was breached:

  • When on-site at your local church eg. Company night, enrolment, display, coffee mornings, rehearsals etc. All breaches must be reported to the GB Captain as soon as possible. The GB Captain must then declare the details of the breach to your designated Data Protection Lead within your church.
  • When off-site from your local church eg. At camp, trip to the local farm, going to the cinema etc. All breaches must be reported to GBHQ immediately.
  • When attending a GBNI or District event eg. Training courses, competitions, one-off events etc. All breaches must be reported directly to the Chairperson of the event. The Chairperson will complete a Data Breach Report Form and should scan the form to GBHQ within 24 hours.

A Data Breach Reporting Form must be completed giving details of the breach and should be passed to the appropriate Data Lead to action immediately. All high risk breaches must be reported to the ICO within 72 hours.

Contacting GBNI

You can contact us by email, telephone or by post.

  • Email: info@gbni.co.uk
  • Telephone: 028 9454 8054
  • Post: GBNI, C2 Kilbegs Business Park, Fergusons Way, Antrim, BT41 4LZ.

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Girls' Brigade Northern Ireland
The Girls’ Brigade Northern Ireland is registered as a company limited by guarantee in Northern Ireland No. NI058531, registered with The Charity Commission for Northern Ireland NIC100405 and recognised as a charity for tax purposes by HMRC Reference No. XR34309. VAT Registration No. 254684143.
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