Last updated August 2018
Policy key definitions:
- “I”, “our”, “us”, or “we” refer to the business, Iulia Calota and Alistair Brownhill.
- “you”, “the user” refer to the person(s) using this website.
- GDPR means General Data Protection Act.
- PECR means Privacy & Electronic Communications Regulation.
- ICO means Information Commissioner’s Office.
- Cookies mean small files stored on a users computer or device.
Processing of your personal data
Under the GDPR (General Data Protection Regulation) we control and/or process any personal information about you electronically in the following ways. Unless otherwise defined, we only process your personal data for accounts and records, advertising, marketing, PR or administration (where applicable) purposes and to provide you with product and services you asked us to provide and perform the required functions to carry out these products and services.
We use the GDPR lawful basis of ‘Contract’ when we need to provide you with details about our services, answer your queries, you ask us to keep you informed regarding a particular course, activity or other product, provide quotes and invoices, and carry out and deliver the services (courses, retreats, holidays, mentoring, editing or any other service) for which you’ve contracted with us to provide.
In the course of answering your queries and taking a booking, we may collect your first and last name, email address, phone number and physical address along with any information you choose to share about your interests in our services. Once you initiate a booking you may share further personal information that helps us tailor our services directly to you as well as adequately provide any necessary arrangements, accommodation and provide a safe environment for you and our other clients.
We shall continue to process your information until the contract between us ends or is terminated under any contract terms. In practice this usually means the end of your holiday rental unless you give explicit consent otherwise and it includes all data you provided us except your name, email address, phone number and which services or products we provided to you. We will retain those as part of our business records and to provide you with the benefits of our returning customers initiative that rewards previous clients with discounts, early booking specials and other ‘previous-clients’ only news, products, opportunities. We also share news and other information that might be of interest to previous clients. The messages are always from us and never from third parties. Every communication includes the ability for you to opt-out of future messages.
We never share any of this information with third parties.
We also use the GDPR lawful basis of ‘Consent’ when you explicitly consent to subscribe to our email mailing list.
Your information is used to send you marketing messages within the scope outlined to you at the point of subscription. We collect the following information from you:
- Your First Name and Last Name
- Email Address
- Date and time you subscribed
We will continue to process your information under this basis until you withdraw consent or it is determined your consent no longer exists. You can unsubscribe or manage your personal information at any time through an online system, which you will find links to in any subscription confirmation email or marketing message we sent to you since.
We never share your information with third parties.
If, as determined by us, the lawful basis upon which we process your personal information changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal information if the lawful basis used is no longer relevant.
Your individual rights
Under the GDPR your rights are as follows. You can read more about your rights in details here;
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object; and
- the right not to be subject to automated decision-making including profiling.
You also have the right to complain to the ICO [www.ico.org.uk] if you feel there is a problem with the way we are handling your data.
We handle subject access requests in accordance with the GDPR.
We do not use any cookies on our website.
Data security and protection
We ensure the security of any personal information we hold by using secure data storage technologies and precise procedures in how we store, access and manage that information. Our methods meet the GDPR compliance requirements.
Transparent Privacy Explanations
We have provided some further explanations about user privacy and the way we use this website to help promote a transparent and honest user privacy methodology.
Email marketing messages & subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the “Processing of your personal data” above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. See any marketing messages for instructions on how to unsubscribe or manage your preferences, you can also unsubscribe from all MailChimp lists, by following this link, otherwise contact the EMS provider.
Our EMS provider is Mail Chimp. We hold the following information about you within our EMS system;
- Email address
- First and last name
- Subscription time & date