WHAT IS THE PURPOSE OF THIS DOCUMENT?
Steph Welch is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. You are being sent a copy of this privacy notice because you are using our services, which includes use of this website (the “Services”) and so that you aware of how and why your personal data will be used, namely for the purposes of the Services, and how long it will usually be retained for. This privacy notice provides you with certain information that must be provided to you, under the General Data Protection Regulation ((EU) 2016/679) (the “GDPR”).
DATA PROTECTION PRINCIPLES
We will comply with data protection law and principles, which means that your data will be:
- Used lawfully, fairly and in a transparent way.
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date.
- Kept only as long as necessary for the purposes we have told you about.
- Kept securely.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
In connection with the Services, we will collect, store, and use the following categories of personal information about you:
- [Information that you have provided in any of the Steph Welch sign up or session forms, including name and personal email address.]
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
We collect personal information about the users of our Services from the following sources:
- You. From the email and name you provide when subscribing to our newsletter
- The following data from third parties is from a publicly accessible source. Data on user behaviour gathered and held by Google, for the purpose of understating the effectiveness of the website to make improvements to the user experience.
HOW WE WILL USE INFORMATION ABOUT YOU
We will use the personal information we collect about you to:
- To send you company newsletters, detailing recent events, activities and content delivered across the Steph Welch online space. To inform you of upcoming events, activities, offers and content.
It is in our legitimate interests to send you interesting and relevant updates on content and offers from Steph Welch. And to understand user behaviour and patterns on our website so that we can continue to improve the experience of our website for you.
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
We will use your particularly sensitive personal information in the following ways:
- We do not collect information about your disability status.
- We do not collect information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, to ensure meaningful equal opportunity monitoring and reporting.
INFORMATION ABOUT CRIMINAL CONVICTIONS
We do not envisage that we will process information about criminal convictions.
You will not be subject to decisions that will have a significant impact on you, based solely on automated decision-making.
Why might we share your personal information with third parties?
We may share personal data we hold with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may also disclose personal data we hold to third parties:
(a) In the event that we sell or buy any business or assets, in which case we may disclose personal data we hold to the prospective seller or buyer of such business or assets.
(b) If we, or substantially all of our assets, are acquired by a third party, in which case personal data we hold will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with you or other agreements; or to protect our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Our third-party service providers are MailChimp for email marketing, this is where we store your name and email address in order to send you newsletters about Steph Welch. We also use Google’s Analytics and AdSense services to collect data on website behaviour and to serve ads on our website as an additional income stream.
All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
TRANSFERRING PERSONAL DATA TO A COUNTRY OUTSIDE THE EEA
We may transfer any personal data we hold to a country outside the European Economic Area (”EEA”), provided that one of the following conditions applies:
(a) The country to which the personal data are transferred ensures an adequate level of protection for your rights and freedoms.
(b) You have given your consent.
(c) The transfer is necessary for one of the reasons set out in GDPR, including the performance of a contract between us and you, or to protect your vital interests.
(d) The transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims.
(e) The transfer is authorised by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of those rights.
Personal data we hold may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. That staff maybe engaged in, among other things, the fulfilment of contracts with you, the processing of payment details and the provision of support services.
The method of transfer is through our third-party application services, such as MailChimp & Google. These third-party services may have servers in countries operating outside the EEA where they store the information we gather from you. These companies are themselves compliant with the GDPR.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will you use my information for?
We will retain your personal information for the purpose of sending email newsletters, until such point where you choose to unsubscribe from this service. We retain your personal information for that period so that we can keep you informed on the latest information associated with Steph Welch. After this period, we will securely destroy your personal information in accordance with applicable laws and regulations.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION Your rights in connection with personal information
Under certain circumstances, by law, you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
If you want to review, verify, correct or request the erasure of your personal information, object to the processing of your personal data or request that we transfer a copy of your personal information to another party, please contact Steph Welch in writing.
RIGHT TO WITHDRAW CONSENT
You have the right to withdraw your consent for processing your information at any time. To withdraw your consent, please contact Steph Welch or unsubscribe to the email newsletter. Once we have received notification that you have withdrawn your consent, we will no longer process your information and, subject to our retention policy, we will dispose of your personal data securely.
DATA PRIVACY MANAGER
We have appointed a data privacy manager to oversee compliance with this privacy notice. If you have any questions about this privacy notice or how we handle your personal information, please contact the data privacy manager Steph Welch.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
I,___________________________, acknowledge that on _________________________ (date), I received a copy of Steph Welch’s Privacy Notice and that I have read and understood it.