by nwad | 10 Feb, 2018 | Uncategorized
If we want to change the way we feel, think or behave we must change our perspective. Part of my role when working with my clients is to help them to see things from a different point of view. When we have feelings, thoughts or behaviours that are a problem for us,...This Privacy Policy sets out how we, Dawn Rowley, collect, store and use information about you when you use or interact with our website, dawnrowley.com (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 18th June 2019.
This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
If you have any questions about this Privacy Policy, please contact the data controller.
The data controller in respect of our website is Dawn Rowley.
You can contact the data controller by completing our contact form.
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
We use a third party server to host our website called SiteGround Hosting Ltd the privacy policy of which is available here: https://www.siteground.co.uk/privacy.htm
Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.
We collect and store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.
We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser use.
We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.
Cookies are data files which are sent from a website to a browser to record information about users for various purposes.
We use cookies on our website, including essential, functional, analytical and targeting cookies. For further information on how we use cookies, please see our cookies policy.
You can reject some or all of the cookies we use on or via our website by changing your browser settings or non-essential cookies by using a cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookie policy.
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
When you contact us using an enquiry form, we collect your personal details and match this to any information we hold about you on record. Typical personal information collected will include your name and contact details. We will also record the time, date and the specific form you completed.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
We will also use this information to tailor any follow up sales and marketing communications with you. For further information, see the section of this privacy policy titled ‘Marketing Communications’.
Messages you send to us via our contact form may be stored outside the European Economic Area on our contact form provider’s servers.
When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.
We record customer-facing phone calls for training and customer service purposes.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you sign up for any of our newsletters from us by completing the newsletter sign up form, we collect your name, email address. We will also record the time and date of completion.
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation). Consent: you give your consent to us sending you our newsletters by signing up to receive them using the steps described above.
We will also use this information to tailor any follow up sales and marketing communications with you. For further information, see the section of this privacy policy titled ‘Marketing Communications’.
Transfer and storage of your information
We use a third-party service to send out our e-newsletter and administer our mailing list, Mailchimp.
Information you submit to subscribe for our e-newsletter may be stored outside the European Economic Area on our third-party mailing list provider’s servers in the United States.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of tracking in emails
We use technologies such as tracking pixels (small graphic files) and tracked links in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates, click through rates and content engagement which our emails achieve.
We have a wide range of social media tools to be able to use on our website. These tools include (but not limited to); Sharing, Likes, comments and submitting content both on and off our website. By using these tools, you are providing your consent to store and use the submitted data whether personal information or general information both on and off our website.
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation). Consent: you give your consent to us storing and using submitted content using the steps described above.
We may also use this information to tailor any follow up sales and marketing communications with you. For further information, see the section of this privacy policy titled ‘Marketing Communications’.
Information you submit may be stored both inside and outside the European Economic Area on our servers as well as third-party servers such as Facebook.
For further information about the safeguards used when your information is transferred outside the European Economic Area.
When you register and create an account on our websites, we collect the following information: your name, email address, address, location. We will also record the time and date of completion.
If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: registering and administering accounts on our website to provide access to content, allows you to buy goods and services and facilitates the running and operation of our business.
We will also use this information to tailor any follow up sales and marketing communications with you. For further information, see the section of this privacy policy titled ‘Marketing Communications’.
Transfer and storage of your information
Information you submit to us via the registration form on our website may be stored outside the European Economic Area on our third-party hosting provider’s servers.
We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
Mandatory information
When you place an order for goods or services on our website, we collect your name, email address, billing address.
If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.
Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions
Additional information
We can also collect additional information from you, such as your phone number, full name, address etc.
We use this information to manage and improve your customer experience with us.
We will also use this information to tailor any follow up sales and marketing communications with you. For further information, see the section of this privacy policy titled ‘Marketing Communications’.
If you do not supply the additional information requested at checkout, you will not be able to complete your order as we will not have the correct level of information to adequately manage your account.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: The ability to provide adequate customer service and management of your customer account.
After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use both PayPal and Stripe, a third party payment processor.
Your payment will be processed by on of the above providers, who collect, use and process your information, including payment information, in accordance with their privacy policies.
You can access PayPal’s privacy policy via the following link: https://www.paypal.com/en/webapps/mpp/ua/privacy-full
You can access Stripe’s privacy policy via the following link : https://stripe.com/en-GB/privacy
Transfer and storage of your information
In providing Card Services, your personal data will be transferred outside the EEA.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.
When signing up for content, registering on our website or making a payment, we will use the information you provide in order to contact you regarding related content, products and services.
We will continue to send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.
You can opt-out from receiving marketing communications at any time by completing our contact form
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: Sharing relevant, timely and industry-specific information on related business services, in order to assist your organisation, grow.
In addition to receiving information about our products and services, you can opt in to receiving marketing communications from us in relation third party goods and services by email by ticking a box indicating that you would like to receive such communications.
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about third party goods and services by signing up to receive such information in accordance with the steps described above.
Transfer and storage of your information
Information for marketing campaigns will be stored outside the European Economic Area on our third-party mailing list provider’s servers in the United States.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of tracking in emails
We use technologies such as tracking pixels (small graphic files) and tracked links in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates, click through rates and content engagement that our emails achieve.
This section sets out how we obtain or collect information about you from third parties.
We can often receive information about you from third parties. The third parties from which we receive information about you can include partner events within the marketing industry and other organisations that we have a professional affiliation with.
It is also possible that third parties with whom we have had no prior contact may provide us with information about you.
Information we obtain from third parties will generally be your name and contact details but will include any additional information about you which they provide to us.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.
For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.
Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.
In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one.
In certain circumstances will also obtain information about you from private sources, both EU and non-EU, such as marketing data services.
We will continue to send you marketing communications in relation to similar goods and services if you do not opt out from receiving them.
You can opt-out from receiving marketing communications at any time by completing our contact form
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: Sharing relevant, timely and industry-specific information on related business services.
If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business
These include the following: Internet services, IT service providers and web developers.
Our third-party service providers are located both inside and outside of the European Economic Area.
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.
We do not display the identities of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).
Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.
Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.
Indicating possible criminal acts or threats to public security to a competent authority
If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber-crime has been committed or if we receive threats or malicious communications towards us or third parties.
We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).
We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.
We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Server log information: we retain information on our server logs for 3 months.
Order information: when you place an order for goods and services, we retain that information for seven years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 36 further month(s), after which point we will archive your information.
Newsletter: we retain the information you used to sign up for our newsletter for as long as you remain subscribed (i.e. you do not unsubscribe).
In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Your information may be transferred and stored outside the European Economic Area (EEA) in the circumstances set out earlier in this policy.
We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to the data controller using the details provided at the top of this policy.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
You can find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here:http://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to the data controller using the details provided at the top of this policy.
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
Our website does not allow you to register any ‘Sensitive Information’, however if we ask for this, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation.
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by contacting us by using the details at the top of this policy.
Strictly Necessary Cookie should be enabled at all times so that we can save your preferences for cookie settings.
If you disable this cookie, we will not be able to save your preferences. This means that every time you visit this website you will need to enable or disable cookies again.
Hello! If you are reading this, then you care about privacy – and your privacy is very important to us. Cookies are an important part of almost all online companies these days, and this page describes what they are, how we use them, what data they collect, and most importantly, how you can change your browser settings to turn them off.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
We use cookies for a number of different purposes. Some cookies are necessary for technical reasons; some enable a personalized experience for both visitors and registered users; and some allow the display of advertising from selected third party networks. Some of these cookies may be set when a page is loaded, or when a visitor takes a particular action (clicking the “like” or “follow” button on a post, for example).
We use cookies for the following purposes:
| Cookie name | Life span | Classification | Purpose |
| _ga | Persistent (2 years) | Performance | Used by Google Analytics to distinguish users |
| _gat
| Persistent (1 Minute) | Performance | Used by Google Analytics to throttle request rate. |
| _gid | Persistent (2 days) | Performance | Used by Google Analytics to distinguish users |
| PHPSESSID | Session | Strictly Necessary | Used to store a generic value to identify your session on our website |
Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
Google Analytics
We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at https://www.google.com/policies/privacy/
Skype/Microsoft Live
We use Skype and Microsoft Live to provide a VOIP and IM facility on our website. You can view Microsoft’s Privacy policy here https://www.skype.com/en/legal/
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:
https://support.google.com/chrome/answer/95647?hl=en
https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
https://www.opera.com/help/tutorials/security/cookies/
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
https://support.apple.com/kb/PH21411
https://privacy.microsoft.com/en-us/windows-10-microsoft-edge
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
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