- Introduction
1.1 I am committed to safeguarding the privacy of my website visitors, service users, individual clients, and their businesses.
1.2 I do not ever ask for more data than is absolutely necessary for me to undertake my services, including your contact information.
1.3. This policy applies where I am acting as a data controller with respect to the personal data of such persons; in other words, where I determine the purposes and means of the processing of that personal data.
1.3 In this policy, “I”, “me” and “my” refers to Bonnie Harrington.[ For more information about us, see Section 14.]
- Credit
2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
- The personal data that I collect
3.1 In this Section 3 I have set out the general categories of personal data that I process.
3.2 I may process data enabling me to get in touch with you (“contact data“). The contact data may include your name, email address, website, and/or social media account identifiers. The source of the contact data is you when you opt to fill in my contact form.
3.4 I may process information relating to transactions, including purchases of goods and/or services, that you enter into with me and/or through my website. This is known as “transaction data“. The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or my payment services provider, such as Stripe. Additionally, I use Dubsado to manage transactions.
3.5 I may process information contained in or relating to any communication that you send to me or that I send to you, known as “communication data“. The communication data may include the communication content and metadata associated with the communication. My website will generate the metadata associated with communications made using the website contact forms. Additionally, I use Dubsado to manage communications.
3.6 I may process data about your use of my website and services, known as “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 data is Google analytics.
- Purposes of processing and legal bases
4.1 In this Section 4, I have set out the purposes for which I may process personal data and the legal bases of the processing.
4.2 Operations – I may process your personal data for the purposes of operating my website, the processing and providing of my services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is my legitimate interest, namely the proper administration of my website, services, and business.
4.3 Relationships and communications – I may process contact data, account data, transaction data and/or communication data for the purposes of managing my relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email and/or telephone, providing support services and complaint handling. The legal basis for this processing is my legitimate interest, namely communications with my website visitors, service users, individual customers, the maintenance of relationships, and the proper administration of my website, services and business.
4.4 Direct marketing – I may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email for marketing-related purposes. The legal basis for this processing is your consent and my legitimate interests, namely promoting my business and communicating marketing messages and offers to my website visitors and service users.
4.5 Research and analysis – I may process usage data and/or transaction data for the purposes of researching and analysing the use of my website and services, as well as researching and analysing other interactions with my business. The legal basis for this processing is my legitimate interest, namely monitoring, supporting, improving and securing my website, services and business generally.
4.6 Record keeping – I may process your personal data for the purposes of creating and maintaining my databases, back-up copies of my databases and my business records generally. The legal basis for this processing is my legitimate interests, namely ensuring that I have access to all the information I need to properly and efficiently run my business in accordance with this policy.
4.7 Security – I 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 my legitimate interest, namely the protection of my website, services and business, and the protection of others.
4.8 Insurance and risk management – I may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is my legitimate interests, namely the proper protection of my business against risks.
4.9 Legal claims – I 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 my legitimate interests, namely the protection and assertion of my legal rights, your legal rights and the legal rights of others.
4.10 Legal compliance and vital interests – I may also process your personal data where such processing is necessary for compliance with a legal obligation to which I am subject or in order to protect your vital interests or the vital interests of another natural person.
- Providing your personal data to others
5.1 I may disclose your personal data to my insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
5.2 Your personal data held in my website database and will be stored on the servers of my hosting services providers. Your data is also held within my administration software account of Dubsado.
5.4 Financial transactions relating to my website and services may be handled by my payment services providers, such as Stripe and Starling. I will share transaction data with my payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
5.5 In addition to the specific disclosures of personal data set out in this Section 5, I may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person. I 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.
- International transfers of your personal data
6.1 In this Section 6, I provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.
6.2 I may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy, during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and I may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.
6.3 The hosting facilities for my website are situated in multiple countries.
6.4 You acknowledge that personal data that you submit for publication through my website or services may be available, via the internet, around the world. I cannot prevent the use (or misuse) of such personal data by others.
- Retaining and deleting personal data
7.1 This Section 7 sets out my data retention policies and procedures, which are designed to help ensure that I comply with my legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that I process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 I will retain your personal data as follows:
(a) Contact data will be retained for a minimum period of 7 years following the date of the most recent contact between you and us, and for a maximum period of 10 years following that date;
(b) Transaction data will be retained for a minimum period of 7 years following the date of the transaction, and for a maximum period of 10 years following that date;
(d) Communication data will be retained for a minimum period of 7 years following the date of the communication in question, and for a maximum period of 10 years following that date;
(e) Usage data will be retained for 7 years following the date of collection; and
7.4 Notwithstanding the other provisions of this Section 7, I may retain your personal data where such retention is necessary for compliance with a legal obligation to which I am subject, or in order to protect your vital interests or the vital interests of another natural person.
- Your rights
8.1 In this Section 8, I 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 me to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask me to erase your personal data;
(d) the right to restrict processing – you can ask me 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 I transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about my processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of my 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/my-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, using the email address: bonnie@wordsbybonnie.com.
- About cookies
9.1 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.
9.2 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.
9.3 Cookies may not contain any information that personally identifies a user, but personal data that I store about you may be linked to the information stored in and obtained from cookies.
- Cookies that I use
10.1 I use cookies for the following purposes:
(a) Authentication and status– I use cookies to identify you when you visit my website and as you navigate my website, and to help me determine if you are logged into my website.
(b) Personalisation – I use cookies to store information about your preferences and to personalise my website for you.
(c) Security – I use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect my website and services generally.
(d) Analysis – I use cookies to help me to analyse the use and performance of my website and services.
- Cookies used by my service providers
11.1 My service providers use cookies and those cookies may be stored on your computer when you visit my website.
11.2 I use Google Analytics, which gathers information about the use of my website and uses cookies for this purpose. I use the information gathered by Google Analytics to create reports about the use of my 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.
11.3 I use Dubsado to manage admin, transactions, contracts, and emails. This service uses cookies. You can view the privacy policy of this service provider at https://www.dubsado.com/legal/privacy-policy.
- Managing cookies
12.1 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); and
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on my website.
- Amendments
13.1 I may update this policy from time to time by publishing a new version on my website.
13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
13.3 I may notify you of significant changes to this policy by email.
- My details
14.1 This website is owned and operated by Bonnie Harrington
14.2 My principal place of business is in Bristol. Please email me for the specific address.
14.3 You can contact me:
(a) Using my website contact form; https://wordsbybonnie.com/contact/
(b) By email, using; bonnie@wordsbybonnie.com
- Data protection officer
15.1 Bonnie Harrington is the data protection officer and can be contacted at the above details.
