Last updated: July 2018
The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore the way this website processes, stores and protects user data and information will also be detailed within this policy.
This website and its owner take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience.
We may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website.
By submitting personal data to us, you agree to us using your personal data as follows.
PERSONAL INFORMATION WE MAY PROCESS
Personal information that we’ll process in connection with all our services, if relevant, includes:
- Personal and contact details, such as full name, email address, telephone number and address
- Records of your contact with us such as via phone or email, or if you get in touch with us online using our contact form
- Products and services you have purchased from us, as well as have been interested in and have held and the associated payment methods used
- Marketing to you and analysing data, including history of those communications, whether you open them or click on links, and information about products or services we think you may be interested in, and analysing data to help target offers to you that we think are of interest or relevance to you.
Any information we collect about you will come either from yourself, any person who may have referred you to us, or from our advertising or social media platforms.
HOW WE MAY USE YOUR DATA
We use your personal data, including any of the personal data listed in section 1 above, for the following purposes:
- Assessing an enquiry for a product or service, including considering whether or not to offer you the product or service
- Managing any aspect of the product or service
- To improve the operation of our business
- For management and auditing of our business operations including accounting
- To keep records of our communications with you
- For market research and analysis and developing statistics
- For direct marketing communications and related profiling to help us to offer you relevant products and service, including deciding whether or not to offer you certain products and service. We may send marketing to you by email, phone, post, social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match).
- For email marketing communications to provide you with relevant information and offers.
- To provide personalised content and services to you, such as tailoring our products and services, our digital customer experience and offerings, and deciding which offers or promotions to show you on our digital channels
- To develop new products and services and to review and improve current products and services
- To comply with legal and regulatory obligations, requirements and guidance
- To interact with live chat platforms
- To carry out remarketing and behavioural targeting (including display ads)
Like many site operators, we collect information that your browser sends whenever you visit our Site.
This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.
In addition, we may use third party services such as Google Analytics that collect, monitor and analyse this data.
LEGAL GROUNDS FOR PROCESSING YOUR INFORMATION
We rely on the following legal bases to use your personal data:
1. Where it is needed to provide you with our products or services, such as:
a) Assessing an enquiry for a product or service you hold with us, including considering whether or not to offer you the product or service
b) Managing products and services you have purchased from us
c) All stages and activities relevant to managing the product or service including enquiry, administration and management of accounts
2. Where it is in our legitimate interests to do so, such as:
a) Managing your products and services relating to that and updating your records
b) For management and audit of our business operations including accounting
c) To keep records of our communications with you
d) For market research and analysis and developing statistics
e) For direct marketing communications and related profiling to help us to offer you relevant products and services, including deciding whether or not to offer you certain products and service. We may send marketing to you by email, phone, post and social media and digital channels (for example, using Facebook Custom Audiences and Google Custom Match)
f) For email marketing communications to provide you with relevant information and offers occasionally.
g) Where we need to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations
3. To comply with our legal obligations
4. With your consent or explicit consent for some direct marketing communications
SHARING YOUR DATA
We may share information with the following third parties for the purposes listed above:
- Governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Prudential Regulation Authority, the Ombudsman, the Information Commissioner’s Office and under the Financial Services Compensation Scheme
- Any other businesses that are needed in order to fulfil our services or products, such as suppliers or outsourcing companies
STORING YOUR DATA
We may use third party tools to store your personal data and keep your information safe, such as a CRM System, cloud storage or email marketing software, as well as our own hard drives and data storage systems.
Your personal data may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”).
PROVIDING US WITH YOUR PERSONAL INFORMATION
We’re unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.
You should tell us so that we can update our records using the details in the Contact Us section of our website. We’ll then update your records if we can.
We may use your home address, phone numbers, email address and social media or digital channels (for example, Facebook, Google and message facilities in other platforms) to contact you according to your marketing preferences. You can stop our marketing at any time by contacting us using the details below or by following the instructions in the communication.
We process and store your personal data for as long as required by the purpose they have been collected for.
- personal data collected for purposes related to the performance of a contract between us and the user will be retained until such contract has been fully performed;
- personal data collected for the purposes of our legitimate interests will be retained as long as needed to fulfill such purposes;
- we may be allowed to retain personal data for a longer period whenever the user has given consent to such processing, as long as such consent is not withdrawn;
- we may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
THIRD PARTY DISCLOSURE
We do not sell, trade, or otherwise transfer to outside parties your personal information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users (such as, for example, our email marketing service provider), so long as those parties agree to keep this information confidential. We may also release information when its release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
YOUR RIGHTS UNDER DATA PROTECTION LAW
Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.
- The right to be informed about the processing of your personal information
- The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
- The right to object to processing of your personal information
- The right to restrict processing of your personal information
- The right to have your personal information erased (the “right to be forgotten”)
- The right to request access to your personal information and to obtain information about how we process it
- The right to move, copy or transfer your personal information (“data portability”)
- Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you
- You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/. You can contact us using the details below.
You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests.
Individuals can find out if we hold any personal information by making a ‘subject access request (SAR)’ under the GDPR law. If we do hold information about you we will:
- Give you a description of it;
- Tell you why we are holding it;
- Tell you who it could be disclosed to; and
- Let you have a copy of the information in an intelligible form.
You can contact us or make an SAR by going to the CONTACT section of our website to exercise these rights or using the contact details below.
These requests can be exercised free of charge and will be addressed by us as soon as possible and always within 30 days.
Sasha Louise Pallari is a brand by Sasha Pallari. Email correspondence should be send to firstname.lastname@example.org.
The security of your personal information is important to us.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.
In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order enters, submits, or accesses their information to maintain the safety of your personal information.
All transactions are processed through a gateway provider and are not stored or processed on our servers.
Unfortunately, no method of transmission over the internet is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
Cookies are small files that hold information; they’re placed or ‘dropped’ on your computer when you access websites or use apps on your device. The data contained in the cookie can be retrieved by the website or app that placed them there. They can also be accessed by websites or apps that have been authorised to use them by the site or app that first dropped them.
Some cookies only exist for a short period of time, and are then automatically deleted by your device. Others last for longer – these are called ‘persistent cookies’ – and some exist for years unless manually deleted. These can be used to analyse multiple site visits over time, or customise the content that’s displayed.
Some cookies are set by the website or app you’re visiting; these are called ‘first party’ cookies. Others may be set by a third party when you use a site or app – for example, by a tool built into the website, or by an advertising network that displays adverts on the site or in the app.
Read more about cookies on the site of the UK Information Commissioner’s Office (who regulated data usage).
COOKIES WE USE
We use the following categories of cookies on the Site:
Strictly necessary cookies
These cookies collect information about your use of the Site, such as for instance, browsing actions, and patterns, the date and time of your visit, the pages viewed, your traffic pattern through the Site.
Through the collection of this information, we are able to monitor and analyse web traffic to the Site. User behaviours may be recognised, collected, and/or tracked.
We use Google Analytics to monitor and analyse web traffic to the Site. Google utilises the data recognised, collected, and/or tracked on the Site to prepare reports on traffic activities.
This integration of Google Analytics anonymises your IP address.
Google may use the information recognised, collected, and/or tracked to personalise the ads of its advertising network and may share the information recognised, collected, and/or tracked with other services.
These cookies allow the Site to save information and details such as your username to optimise your experience on the Site and provide personal features.
Third Party cookies
Vimeo video widget
Vimeo is a video sharing website that allows this Site to incorporate video content on its pages and posts.
Ticket Tailor widget
Ticket Tailor is a ticket selling website that allows this Site to incorporate ticket selling facilities on its pages and posts.
COOKIES ON WEBSITES WE LINK TO
We often link to other sites to give you extra information or services. Where these are provided by a third party, you may leave our website by clicking through to theirs. In this case, the cookies policy set out on the third party’s website will also apply. As this won’t be controlled by us, you should read their policy to find out what information is being collected and how it’s used.
HOW TO CONTROL COOKIES
Strictly necessary cookies may not be rejected since they are essential to enable you to browse the Site and use its features.
Should you reject cookies, you will still be able to use the Site although certain features and functionalities may not be available to you and/or certain areas may be restricted.
Through browser preferences, it is also possible to delete cookies installed in the past, including the cookies that may have saved the initial consent for the installation of cookies by this Site.
You can find information about how to manage cookies in the most commonly used browsers (e.g. Google Chrome, Mozilla Firefox, Apple Safari, and Microsoft Internet Explorer) on the website of the browser of choice.
To find out more about Cookies, including how to control, opt-out and delete them, go to http://www.aboutcookies.org for guidance.