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PRIVACY AND COOKIES POLICY

1.     Introduction

1.1    We are committed to safeguarding the privacy of our website visitors

1.2   This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and                    means of the processing of that personal data.  

1.3    We use cookies on our website.  Insofar as those cookies are not strictly necessary for the provision of our website, we will ask you to consent to our use of cookies when

        you first visit our website.

1.4    In this policy, "we", "our" and "us" refer to Melanie Hill.  For more information about us, see Section 17.

2.      The personal data that we collect

2.1     In this Section 2, we have set out the general categories of personal data that we process.

2.2     We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address

         and / or social media account identifiers.  The source of the contact data is you.  If you provide contact details using a social media account, we will obtain elements

         of the contact data from the relevant social media account provider.

2.3     We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data").  The communication

         data may include the communication content and metadata associated with the communication.  Our website will generate the metadata associated with 

         communications made using the website contact forms.   

2.4     We may process data about your use of our website and services ("usage data").  The usage data may include your IP address, geographical location, browser type and 

          version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of

          your service use.  The source of the usage is our analytics tracking system.  

2.5      Please do not supply any other person's personal data to us.

3.       Purposes of processing and legal bases

3.1     In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.

3.2     Operations - We may process your personal data for the purposes of operating our website and providing our services.  The legal basis for this processing is our

         legitimate interests, namely the proper administration of our website, services and business or the performance of a contract between you and us or taking steps, at

         your request, to enter into such a contract. 

3.3     Research and analysis - We may process usage data, service data and / or transaction data for the purposes of researching and analysing the use of of our website and 

         services, as well as researching and analysing other interactions with our business.  The legal basis for this processing is our legitimate interests, namely monitoring,

         supporting, improving and securing our website, services and business generally.

3.4    Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business

         records generally.  The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and

         efficiently run our business in accordance with this policy.

3.5     Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity.  The legal basis of this processing

         is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

3.6     Insurance and risk management - We may process your personal data where necessary for the purposes of managing risks and / or obtaining professional advice.

         The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3.7     Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an 

         administrative or out-of-court procedure.  The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your

         legal rights and the legal rights of others.

3.8    Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are 

         subject or in order to protect your vital interests or the vital interests of another natural person.

4.       Providing your personal data to others

4.1     We may disclose your personal data to our insurers and / or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance

          coverage, managing risks or obtaining professional advice.

4.2      Your personal data held in our website databases will be stored on the servers of our hosting services providers.  See information for "Users of users" at 

           https://www.wix.com/manage/privacy-security-hub

4.3      In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance 

           with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.  We may also disclose your 

          personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-

          -of-court procedure.

5.        International transfers of your personal data

5.1      In this Section 5, we provide information about the circumstances in which your personal data may be transferred to a third country under UK data protection law OR

          EU data protection law.

5.2     The hosting facilities for our website are situated in Israel.  The competent data protection authorities have made an adequacy determination with respect to the data

          protection laws of this country.  Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or

          approved by the competent data protection authorities, a copy of which your can obtain from https://www.wix.com/about/privacy

5.3      You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world.  We cannot

           prevent the use or misuse of such personal data by others.

6.        Retaining and deleting personal data

6.1       This Section 6 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the 

            retention and deletion of personal data.

6.2       Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose. 

           a) Contact data will be retained for the minimum period of facilitating communication between you and us, will be retained for a maximum period of 7 years.

6.3       Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation 

           to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

7.        Security of personal data

7.1       We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.

7.2       We will store your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.  We are required to 

            maintain session notes for 7 years.

7.3        Data relating to your enquiries that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using 

            encryption technology.

7.4       You acknowledge that the transmission of un-encrypted (or inadequately encrypted), data over the internet is inherently insecure, and we cannot guarantee the 

            of data sent over the internet.

8.         Your rights

8.1        In this Section 8, we have listed the rights that you have under data protection law.

8.2        Your principal rights under data protection law are:

             (a)  the right to access - you can ask for copies of your personal data;

             (b)  the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

             (c)  the right to erasure - you can ask us to erase your personal data;

             (d)  the right to restrict processing - you can ask us to restrict the processing of your personal data;

             (e)  the right to object to processing - you can object to the processing of your personal data;

             (f)  the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

             (g)  the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

             (h)  the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

 

8.3        These rights are subject to certain limitations and exceptions.  You can learn more about the rights of data subjects by visiting

             https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en    and

             https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

8.4        You may exercise any of your rights in relation to your personal data by written notice to us.

8.5        You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain

             additional information.  That additional information includes details of the purposes of the processing, the categories of personal data concerned and the 

             recipients of the personal data.  Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.

8.6        You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete 

              personal data about you completed.

8.7         In some circumstances you have the right to the erasure of your personal data without undue delay.  Those circumstances include: the personal data are no 

              longer necessary in relation to the purposes for which they were collected or otherwise processed.  However, there are exclusions of the right to erasure.  The

              general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal

              obligation; or for the establishment, exercise or defence of legal claims.

8.8         In some circumstances you have the right to restrict the processing of your personal data.  Those circumstances are: you contest the accuracy of the personal data; 

              processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the 

              establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection.  Where processing has been

              restricted on this basis, we may continue to store your personal data.  However, we will only otherwise process it: with your consent: for the establishment,

              exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

8.9         You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis

              for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority

              vested in us; or the purposes of the legitimate interests pursued by us or by a third party.  If you make such an objection, we will cease to process the personal 

              data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for

              the establishment, exercise or defence of legal claims.

8.10        To the extent that the legal basis for our processing of your personal data is:

               (a)  consent; or

               (b)  that the processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a

                      contract.

               You have the right to receive your personal data from us.  However, this right does not apply where it would adversely affect the rights and freedoms of others.

8.11         If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority

               responsible for data protection.  In relation to complaints under EU data protection law, you may do so in the EU member state of your habitual residence, place

               of work or the place of the alleged infringement; in relation to complaints under UK data protection law, you should do so in the UK.

8.12         To the extent that the legal basis for our processing of your personal data is consent, you have the right to withdraw that consent at any time.  Withdrawal will not

                affect the lawfulness of the processing before the withdrawal.  

8.13          You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.

9.            Third party websites

9.1           Our website includes hyperlinks to, and details of, third party websites.

9.2           In general we have no control over, and are not responsible for, the privacy policies and practices of third parties.

10.           Personal data of children

10.1          Our website and services are targeted at persons over the age of 18.

10.2          If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

11.            Updating information

11.1           Please let us know if the personal information that we hold about you needs to be corrected or updated.

12.            About cookies

12.1           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.

12.2           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.

12.3           Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information 

                 stored in and obtained from cookies.

13.            Cookies that we use

13.1           We use cookies for the following purposes:

13.2           analysis - we use cookies to help us analyse the use and performance of our website and services.

14.            Cookies used by our service providers

14.1           Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

14.2           We use Google Analytics which gathers information about the use of our website and uses cookies for this purpose.  We use the information gathered by

                 Google Analytics  to create reports about the use of our website.  You can find out more about Google's use of information by visiting

                 https://policies.google.com/technologies/partner-sites  and you can review Google's privacy policy at https://policies.google.com/privacy

                 The cookies used by Google Analytics are named _ga and _ga+container-id.

15.             Managing cookies

15.1           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 obtain up-to-date  information about managing cookies via these links:

                 

                 (a)   https://support.google.com/chrome/answer/95647   (Chrome)

                 (b)   https://support.mozilla.org/en-US/products/firefox/privacy-and-security   (Firefox)

                 (c)   https://help.opera.com/en/latest/security-and-privacy/   (Opera)

                 (d)   https://support.apple.com/en-gb/guide/safari/welcome/mac   (Safari)

                 (e)   https://support.microsoft.com/en-gb/windows/microsoft-edge-browsing-data-and-privacy-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd   (Edge)

15.2           Blocking all cookies will have a negative impact upon the usability of many websites.

16.             Amendments

16.1           We may update this policy from time to time by publishing a new version on our website.

16.2           You should check this page occasionally to ensure you are happy with any changes to our policy.

16.3           We may notify you of significant changes to this policy.

17.             Our details

17.1           This website is owned and operated by Melanie Hill.

17.2            Our principal place of business is 10 Daniel Court, Stamford, Lincs PE9 2GJ

17.3            You can contact us:

                  (a)   by post, to the postal address given above

                  (b)   using our website contact form

                  (c)    by telephone, on the contact number published on our website

                  (d)    by email, using the  email address published on our website.

18.             Data protection registration

18.1           We are registered as a data controller with the UK Information Commissioner's Office.

18.2           Our data protection registration number is ZB624864

19.             Representatives

19.1            Our representative within the UK with respect to our obligations under data protection law is Melanie Hill and you can contact our representative

                  by any of the methods above.

20.             Data protection officer

20.1            Our data protection officer's contact details are as detailed above.

                 

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