Lesley Whiteman Social Media Privacy Policy

RIVER DREAMS LTD – PRIVACY NOTICE
(updated May 2018)

INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our sites www.lesleywhitemansocialmedia.co.uk and www.sheffordlocal.co.uk

By providing us with your data, you warrant to us that you are over 13 years of age.

LESLEY WHITEMAN is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Contact Details

Our full details are:

Full name of legal entity: River Dreams Ltd T/A Lesley Whiteman Social Media and Shefford Local / Shefford & Local Villages

Email address: lesley@lesleywhitemansocialmedia.co.uk and lesley@sheffordlocal.co.uk

Postal address: 68 Ampthill Rd, Shefford, Bedfordshire, SG17 5BB.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at lesley@lesleywhitemansocialmedia.co.uk

GENERAL DATA PROTECTION REGULATION (GDPR) COMPLIANCE:

Data security: data is protected by online and physical measures which are reviewed and updated as considered appropriate. We hold only name, address, phone and email data, plus client passwords.

In general, data is held or processed on the basis of legitimate commercial interests and by consent of individuals. Where appropriate we will hold data for the service of contracts, compliance with legal obligation or possibly for a public task.

So for example most data is held for commercial and for administration purposes, for update of information, e.g. by email, newsletter, phone calls.

Data is held so long as it is considered necessary, relevant, in the interests of the data subject, or as required by law.

We will not share your personal data without consent unless under legal direction. You have the right to inspect, update, change or delete any information held on you personally – you may do so by contacting “the data controller at Lesley Whiteman Social Media” and we will deal with it promptly.

WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE, AND ON WHAT GROUNDS WE PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details and purchase details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising.  Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).

Sensitive Data. We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at lesley@lesleywhitemansocialmedia.co.uk In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

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

HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies.

Our website uses cookies – small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics.

As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.

Our cookie audit shows:

  1. Essential session log and download cookies – anonymous and essential registration log cookies used when visitors subscribe or register for additional services.
  2. Google Analytics tracking cookies – anonymously track visitor site usage. For details of how to opt out of Analytics please click here.
  3. YouTube tracking cookies – anonymously track visitor site usage when videos are played through this site. To find out more please click here.

For more information please also see your browser options as this may enable you to disallow cookies.

If you are using Internet Explorer or Microsoft Edge you can get more information on cookies and how to disable them from the Microsoft website.

If you are using Mozilla Firefox you can get more information on cookies and how to disable them here.
If you are using Google Chrome you can get more information on cookies and how to disable them here.

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators. As a result of this usage, you may see ads for our products or services based on your viewing of our websites.

Additionally, we may use custom audiences based on email addresses of subscribers and customers. This allows us to present offers of our products and services to you via Facebook.

We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

MARKETING COMMUNICATIONS

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by emailing us at lesley@lesleywhitemansocialmedia.co.uk or lesley@sheffordlocal.co.uk at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers
  • Government bodies that require us to report processing activities.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

Countries outside of the European Economic Area do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

If our third parties service providers are based outside the European Economic Area so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:

We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or

Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

DATA SECURITY

Data is protected by online and physical measures which are reviewed and updated as considered appropriate.

DATA RETENTION

In general, data is held or processed on the basis of legitimate commercial interests and by consent of individuals.  Data is held so long as it is considered necessary, relevant, in the interests of the data subject, or as required by law.

We are happy to provide copies of information held on receipt of a “subject access request” under the General Data Protection Regulation 2018.

YOUR LEGAL RIGHTS

Information on your legal rights is available at:

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

COMPLAINTS
We undertake to log your complaint thoroughly, to investigate it and respond. We will take action and apologise as considered appropriate and proportionate.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

CONDITIONS OF USE
By using our website it is a condition of use that visitors accept the terms of our privacy policy.