Privacy

Website Privacy Policy

BACKGROUND:


  • This Policy applies as between you, the User of this Website and Katrina Robinson the owner and provider of this Website katrinarobinson.co.uk. All processing activities shall be carried out in accordance with your individual rights as defined by the European Union’s General Data Protection Regulation and UK GDPR. The UK is committed to maintaining the high standards of the GDPR and the government has incorporated it into UK law (the UK GDPR) alongside the Data Protection Act 2018.


This Policy applies to our use of any and all Data collected by us in relation to your use of the Website and any Services or Systems therein.


1.                Important information

1.1             Our Website is not intended for children and we do not knowingly collect data relating to children.

1.2             This Privacy Policy supplements the other policies (including our terms of use (Terms)) and is not intended to override them.

1.3             Katrina Robinson is the controller and responsible for your personal data (we, us or our).

1.4             To assist you further in understanding this Privacy Policy, we have set out in Part 5 of Schedule 1 a glossary of terms used, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.

1.5             We have appointed a data privacy manager (DPM). If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our DPM in writing:

1.6             By email to: katrina@katrinarobinson.co.uk

1.7             You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.8             Our Website may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control over these third-party websites, plug in or applications and are not responsible for their privacy policies, therefore you should also read their privacy policy to understand what personal data they collect about you and how they use it.


2.                The data we collect about you

2.1             We may collect, use, store and transfer the types of personal data about you listed in Part 1 Schedule 1

2.2             We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.

2.3             We do not collect any special categories of personal data.

2.4             If we are required by law, to collect your personal data and you fail to provide it, we may not be able to enter into perform the contract with you and, we may have to cancel a product or service. We will notify you of this at the relevant time.


3.                How personal data is collected

We collect personal data in the following ways:

3.1             Direct interactions. You may provide personal data when you complete online forms, request services, subscribe to my services (if any), join my mailing list, or otherwise or correspond with me (by post, phone or email). 

3.2             Automated technology. We automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies, and other similar technologies.

3.3              Third parties. We may receive personal data from: (a) analytics providers based outside the EU (such as Google); (b) advertising networks inside OR outside the EU; and (c) search information providers inside OR outside the EU; (d) our suppliers such as payment providers, delivery services, website support and maintenance providers.


4.                How we use your personal data

4.1             We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:

4.2             To perform the contract, we are to enter into or have entered into with you;

4.3             To comply with a legal obligation; and

4.4             Where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

4.5             Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.

4.6             We do generally only rely on consent as a legal basis for processing your personal data to send email and SMS marketing communications and you have the right to withdraw your consent at any time by contacting us. Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information.

4.7             We may analyse your personal data to form a view on what products and or services we think may be of interest to you. You will only receive marketing communications from us, if you have requested information from us or purchased services from us, if you consent to marketing at the time we collect your personal data and you have not subsequently opted out or withdrawn your consent or if we have another basis to send you the marketing communications.

4.8             We will not share your personal data with third parties for their marketing purposes.

4.9             You can opt out of email marketing by clicking the unsubscribe button within the marketing email. You can also withdraw your consent to marketing at any time by contacting our DPM.

4.10          Even if you opt out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so.

4.11          We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

4.12          If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to use your personal data in this manner.

4.13          We may process your personal data (without your knowledge or consent) where this is required or permitted by law.


5.                Disclosure of your personal data

5.1             We may have to share your personal data with third parties, further details of which are set out in Part 4 of Schedule 1. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. They can only process your personal data for specified purposes and in accordance with our instructions.


6.                International transfers

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

6.2             We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

6.3             We use specific contracts approved by the European Commission which give personal data the same protection it has in Europe and the UK with our services providers; 

6.4             We may transfer data to US based service providers under the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

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


10.                Changes to this Policy

10.1             Katrina Robinson reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Policy on your first use of the Website following the alterations.



11.                Cookies

11.1             We and our trusted partners use cookies and other technologies in our related services, including when you visit our site or access our services. 

11.2             A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

11.3             The Site uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ' which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third-party cookies' which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyse our web access.

11.4             Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.
11.5             We also use a tool called “Google Analytics” to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, which pages they visit, when they do so. We use the information we obtain from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics 
Terms of Use and the Google Privacy Policy.

11.6             Before the Website sets Cookies on your computer, you will be presented with a Pop-up message bar informing you of those Cookies and a selection to accept or decline as follows:

“This site uses third-party website tracking technologies to provide and continually improve our services, and to display advertisements according to users' interests. I agree and may revoke or change my consent at any time with effect for the future.”

11.7             When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

11.8             By giving your consent to the setting of our Cookies you are enabling us to provide the best possible experience and service to you through our Website. If you wish to deny your consent to the placing of Cookies, certain features of the Website may not function fully or as intended.

11.9             We collect two types of data and information from Users. 

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time) in order to enhance the functionality of our Site. We may also collect information about your activity on the Site (e.g. pages viewed, online browsing, clicks, actions).

The second type of information Personal Information which is individually identifiable information, namely information that identifies an individual or may, with reasonable effort, identify an individual. Such information includes:

Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.

11.10          Certain features of the Website depend upon Cookies to function and are deemed, within the law, to be strictly necessary and are called essential. In There are also cookies related to Marketing and Functional. These Cookies are detailed in Usercentrics Consent Management tool where full details for their use and data retention are described. You will not be asked for your consent to place these Cookies however you may still disable cookies via your web browser’s settings, as set out in sub-Clause 11.4.

11.11          You can choose to enable or disable Cookies in your web browser. By default, your browser will accept Cookies, however, this can be altered. For further details please consult the help menu in your browser. Disabling Cookies may prevent you from using the full range of Services available on the Website.

11.12          You may delete Cookies at any time however you may lose any information that enables you to access the Website more quickly.

11.13          It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your browser if you are unsure as to how to adjust your privacy settings.

11.14           By viewing embed YouTube videos you by the applicable YouTube Terms of Service. In addition to our normal procedure for deleting stored data, users can revoke that our access to your data via the Google security settings page.


Schedule 1: Personal Data Part 1: Types of personal data

S1-P1 1. Contact data: billing address, delivery address, email address and telephone number.

S1-P1 2. Financial data: bank account and payment card details.

S1-P1 3. Identity data: first name, maiden name, last name, username or similar identifier.

S1-P1 4. Marketing and communication data: your preferences in receiving marketing from us and our third parties and your communication preferences.

S1-P1 5. Profile data: your username and password, purchase or orders made by you, preferences, feedback.

S1-P1 6. Technical data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

S1-P1 7. Transaction data: details about payments to and from you and other details of products and services you have purchased from us.


Schedule 1: Personal Data. Part 2: Lawful basis for processing and processing activities 

S1-P2 1. Consent: you have given your express consent for us to process your personal data for a specific purpose

S1-P2 2. Contract: the processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you

S1-P2 3. Legal obligation: the processing is necessary for us to comply with legal or regulatory obligation.

S1-P2 4. Legitimate interests: the processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our website. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest.


Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this:


Purpose/Activity Type of data Lawful basis for processing
to register you as a new customer identity & contact to perform our contract with you
to process and deliver your order, manage payments, fees and charges and debt recovery identity, contact, financial, transaction and marketing & communications (i) to perform our contract with you;(ii) as necessary for our legitimate interest in recovering debts due to us.
to manage our relationship with you, notifying you about changes to our Terms or Privacy Policy and ask you to leave a review or take a survey identity, contact, profile & marketing & communications (i) to perform our contract with you (ii) as necessary to comply with a legal obligation(iii) as necessary for our legitimate interests in keeping our records updated and analysing how customers use our products/services
to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) identity, contact & technical (i) as necessary for our legitimate interests in running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise(ii) as necessary to comply with any legal obligations
to deliver relevant website content/advertisements to you and measure or understand the effectiveness of our advertising identity, contact, profile, usage, marketing & communications & technical as necessary for our legitimate interests in studying how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
to use data analytics to improve our website, products/services, marketing, customer relationships and experiences technical & usage as necessary for our legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
to make suggestions and recommendations to you about goods or services that may be of interest to you, including promotional offers identity, contact, technical, usage & profile as necessary for our legitimate interests to develop our products/services and grow our business

Schedule 1: Personal Data. Part 3: Your legal rights
You have the following legal rights in relation to your personal data:

S1-P3 1. Access your data: you can ask for access to and a copy of your personal data and can check we are lawfully processing it

S1-P3 2. Correction: you can ask us to correct any incomplete or inaccurate personal data we hold about you

S1-P3 3. Erasure: you can ask us to delete or remove your personal data where:

(a) there is no good reason for us continuing to process it;

(b) you have successfully exercised your right to object (see below);

(c) we may have processed your information unlawfully; or 

(d) we are required to erase your personal data to comply with local law. 

(e) We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request

S1-P3 4. Object: you can object to the processing of your personal data where:

(a) where we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms;

(b) where we are processing your personal data for direct marketing purposes.

(c) in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms, and, in such circumstances, we can continue to process your personal data for such purposes

S1-P3 5. Restrict processing: you can ask us to us to suspend or restrict the processing of your personal data, if:

(a) you want us to establish the accuracy of your personal data;

(b) our use of your personal data is unlawful, but you do not want us to erase it;

(c) you need us to hold your personal data (where we no longer require it) as you need it to establish, exercise or defend legal claims; or

(d) you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it

S1-P3 6. Request a transfer: you can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contact with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format

S1-P3 7. Withdraw your consent: you can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent.


Schedule 1: Personal Data. Part 4: Third Parties
S1-P4 1. Service providers: acting as processors or controllers based in the EEA but also around the world who provide IT and system administration services.

S1-P4 2. Professional advisors: including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services

S1-P4 3. HM Revenue & Customs, regulators and other authorities: based in the EEA who require reporting of processing activities in certain circumstances

S1-P4 4. Third parties: third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.


Schedule 1: Personal Data. Part 5: Glossary
Aggregated data: information such as statistical or demographic data which may be derived from personal data, but which cannot by itself identify a data subject

Controller: a body that determines the purposes and means of processing personal data

Data subject: an individual living person identified by personal data (which will generally be you)

Personal data: information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data

Processor: a body that is responsible for processing personal data on behalf of a controller

Special categories of personal data: information about race, ethnicity political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, sexual orientation.

ICO: Information Commissioner’s Office, the UK’s supervisory authority for data protection issues
Third party cookies as listed in the Usercentrics Consent Management platform. You can exercise preferences about what cookies are served on our Sites by using this tool.

By viewing embed YouTube videos you by the applicable . In addition to our normal procedure for deleting stored data, users can revoke that our access to your data via the 


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