Privacy Policy

Privacy Policy

This is the privacy notice of Niki Buskell.

Introduction

This notice describes how I collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

Except as set out below, I do not share, or sell, or disclose to a third party, any information collected through this website.

Personal data I process

1. How I obtain personal data

The information I process about you includes information:· you have directly provided to me
· that I gather from third party databases and service providers
· as a result of monitoring how you use my website or services

2. Types of personal data I collect directly

When you use my website, my services or buy from me, I may ask you to provide personal data. This can be categorised into the following groups:
· personal identifiers, such as your first and last names, your title and your date of birth
· contact information, such as your email address, your telephone number and your postal addresses for billing, delivery and communication
· payment information, such as a debit or credit card number and expiry date and bank account details
· records of communication between us including messages sent through our website, email messages and telephone conversations
· marketing preferences that tell us what types of marketing you would like to receive

3. Types of personal data I collect from third parties

I confirm some of the information you provide to me directly using data from other sources. I also add to the information I hold about you, sometimes to remove the need for you to provide it to me and sometimes in order to be able to assess the quality of the services we offer.The additional information we collect can be categorised as follows:

· information that confirms your identity
· business information, including your business trading name and address, your company number (if incorporated), and your VAT number (if registered)
· information that confirms your contact information

4. Types of personal data we collect from your use of our services

By using my website and services, I process:

· information you contribute to my community, including reviews
· your replies to polls and surveys
· technical information about the hardware and the software you use to access my website and use my services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
· usage information, including the frequency you use my services, the pages of my website that you visit, whether you receive messages from me and whether you reply to those messages
· transaction information that includes the details of the products services you have bought from me and payments made to me for those services
· your preferences to receive marketing from me; how you wish to communicate with me; and responses and actions in relation to your use of my services.

5. My use of aggregated information

I may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.For example, I may aggregate usage information to assess whether a feature of my website is useful.

However, if I combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.

6. Special personal data

Special personal data is data 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.

7. If you do not provide personal data I need

Where I need to collect personal data by law, or under the terms of a contract I have with you, and you fail to provide that data when requested, I may not be able to perform that contract.

In that case, I may have to stop providing a service to you. If so, I will notify you of this at the time.

The bases on which I process information about you.

The law requires us to determine under which of six defined bases I process different categories of your personal data, and to notify you of the basis for each category.

If a basis on which I process your personal data is no longer relevant then I shall immediately stop processing your data.
If the basis changes, then if required by law I shall notify you of the change and of any new basis under which I have determined that I can continue to process your information.

8. Information I process because I have a contractual obligation with you

When you buy a product or service from me, or otherwise agree to our terms and conditions, a contract is formed between you and me.

In order to carry out my obligations under that contract I must process the information you give me. Some of this information may be personal data.

I may use it in order to:
· verify your identity for security purposes when you use my services
· sell services to you
· provide you with my services
· provide you with suggestions and advice on products, services and how to obtain the most from using our website

I process this information on the basis there is a contract between us, or that you have requested I use the information before I  enter into a legal contract.

I shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

9. Information I process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse my website or ask me to provide you more information about my business, including products and services, you provide your consent to me to process information that may be personal data.

Wherever possible, I aim to obtain your explicit consent to process this information, for example, I ask you to agree to my use of non-essential cookies when you access my  website.

If you have given explicit permission to do so, I may from time to time pass your name and contact information to selected associates whom I consider may provide services or products you would find useful.

I continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing me at hello@nikibuskell.com. However, if you do so, you may not be able to use my website or services further.

I aim to obtain and keep your consent to process your information. However, while I take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent me from continuing to process it. The law may allow me to continue to process your personal data, provided that there is another basis on which we may do so. For example, I may have a legal obligation to do so.

10. Information I process for the purposes of legitimate interests

I may process information on the basis there is a legitimate interest, either to you or to me, of doing so.

Where I process your information on this basis, I do after having given careful consideration to:
· whether the same objective could be achieved through other means
· whether processing (or not processing) might cause you harm
· whether you would expect me to process your data, and whether you would, in the round, consider it reasonable to do so
For example, I may process your data on this basis for the purposes of:
· improving my services
· record-keeping for the proper and necessary administration of my business
· responding to unsolicited communication from you to which I believe you would expect a response
· preventing fraudulent use of my services
· exercising my legal rights, including to detect and prevent fraud and to protect my  intellectual property
· insuring against or obtaining professional advice that is required to manage organisational risk
· protecting your interests where I believe I  have a duty to do so

11. Information I process because I have a legal obligation

Sometimes, I must process your information in order to comply with a statutory obligation.

For example, I may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal data.

12. Information I process to protect vital interests

In situations where processing personal information is necessary to protect someone’s life, where consent is unable to be given and where other lawful bases are not appropriate, I may process personal information on the basis of vital interests.

How and when I process your personal data

13. Your personal data is not shared

I do not share or disclose to a third party, any information collected through our website.

14. Information you provide

My website allows you to leave information with a view to that information being read, copied, downloaded, or used by us.
For example, when you send a message through my website, I reasonably assume that you consent for the message to be seen by me. I may include your name with your message, and your message may contain information that is personal data.

15. Job application and employment

If you send us information in connection with a job application, I may keep it for up to three years in case I decide to contact you at a later date.

If I employ you, I collect information about you and your work from time to time throughout the period of your employment. This information will be used only for purposes directly relevant to your employment. After your employment has ended, I will keep your file for six years before destroying or deleting it.

16. Information obtained from third parties

Although I do not disclose your personal data to any third party (except as set out in this notice), I sometimes receive data that is indirectly made up from your personal data from third parties whose services I use.

No such information is personally identifiable to you.

17. Third party advertising on my website

Third parties may advertise on my website.

In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on my website.
They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.

I do not have control over these technologies or the data that these parties obtain.

Accordingly, this privacy notice does not cover the information practices of these third parties.

18. Service providers and business partners

I may share your personal data with businesses that provide services to me, or with business partners.
As examples:
· I may pass your payment information to our payment service provider to take payments from you
· I may use fraud prevention agencies and credit reference agencies to verify your identity
· I may pass your contact information to advertising agencies to use to promote my  services to you

19. Referral partners

This is information given to me by you in your capacity as an affiliate of me or as a referral partner.

It allows me to recognise visitors that you have referred to me, and to credit to you commission due for such referrals. It also includes information that allows me to transfer commission to you.

The information is not used for any other purpose.

I undertake to preserve the confidentiality of the information and of the terms of our relationship.

I expect any affiliate or partner to agree to reciprocate this policy.

Use of information I collect through automated systems

20. Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.
They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.

Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.
When you first visit my website, I ask you whether you wish us to use cookies. If you choose not to accept them, I shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of our website.

I use cookies in the following ways:
· to track how you use our website
· to record whether you have seen specific messages I display on my website
· to record your answers to surveys and questionnaires on my site while you complete them

21. Personal identifiers from your browsing activity

Requests by your web browser to my servers for web pages and other content on my  website are recorded.

I record information such as your geographical location, your Internet service provider and your IP address. I also record information about the software you are using to browse my website, such as the type of computer or device and the screen resolution.

I use this information in aggregate to assess the popularity of the webpages on my  website and how I perform in providing content to you.

If combined with other information I  know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to our website.

22. Re-marketing

Re-marketing involves placing a ‘tracking technology’ such as a cookie, a ‘web beacon’ (also known as an ‘action tag’ or a ‘single-pixel GIF’) to track which pages you visit and to serve you relevant adverts for my  services when you visit some other website.

The benefit of re-marketing technology is that I can provide you with more useful and relevant adverts, and not show you ones repeatedly that you may have already seen.
I may use a third-party advertising service to provide me with re-marketing services from time to time. If you have consented to my use of such tracking technologies, you may see advertisements for my products and services on other websites.

I do not provide your personal data to advertisers or to third-party re-marketing service providers. However, if you are already a member of a website whose affiliated business provides such services, that affiliated business may learn of your preferences in relation to your use of our website.

Other matters

23. Your rights

The law requires me to tell you about your rights and my obligations to you in regard to the processing and control of your personal data.

I do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org

24. Use of our services by children

I do not sell products or provide services for purchase by children, nor do we market to children.

If you are under 18, you may use our website only with consent from a parent or guardian.
We collect data about all users of and visitors to these areas regardless of age, and we anticipate that some of those users and visitors will be children.

 

25. Encryption of data sent between us

I use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

26. Delivery of services using third party communication software

With your consent, I may communicate using software provided by a third party such as Facebook (WhatsApp),  Microsoft (Skype) or Zoom Video Communications (Zoom).

Such methods of communication should secure your personal data using encryption and other technologies. The providers of such software should comply with all applicable privacy laws, rules, and regulations, including the GDPR.

If you have any concerns about using a particular software for communication, please tell me.

27. Data may be processed outside the UK

My websites are hosted in the UK.
I may also use outsourced services in countries outside the UK from time to time in other aspects of our business.

Accordingly, data obtained within the UK or any other country could be processed outside the UK.

I use the following safeguards with respect to data transferred outside the UK:
· the processor is within the same corporate group as our business or organisation and abides by the same binding corporate rules regarding data processing.
· the data protection clauses in our contracts with data processors include transfer clauses written by or approved by a supervisory authority.

28. Control over your own information

It is important that the personal data I hold about you is accurate and up to date. Please inform me if your personal data changes.

When I receive any request to access, edit or delete personal data I first take reasonable steps to verify your identity before granting you access or otherwise taking any action.

This is important to safeguard your information.

Please be aware that I am not obliged by law to provide you with all personal data I hold about you, and that if I do provide you with information, the law allows me to charge for such provision if doing so incurs costs for me. After receiving your request, I will tell you when I expect to provide you with the information, and whether I require any fee for providing it to you.

If you wish me to remove personally identifiable information from my website, you should contact me to make your request.

This may limit the service I can provide to you.

I remind you that I am not obliged by law to delete your personal data or to stop processing it simply because you do not consent to me doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which I may process it, I may do so on that basis.

29. Communicating with me

When you contact me, whether by telephone, through my website or by email, I collect the data you have given to me in order to reply with the information you need.

I record your request and reply in order to increase the efficiency of the business.

I may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

30. Complaining

If you are not happy with my privacy policy, or if you have any complaint, then you should contact me immediately.

When I receive a complaint, I record the information you have given on the basis of consent. I use that information to resolve your complaint.

I aim to investigate all complaints relating to user generated content. However, I may not be able to do so as soon as a complaint is made. If we feel that it is justified or if I believe that the law requires me to do so, I shall remove the content while do so.

If I think your complaint is vexatious or without any basis, I shall not correspond with you about it.

If your complaint reasonably requires me to notify some other person, I may decide to give to that other person some of the information contained in your complaint. I do this as infrequently as possible, but it is a matter for my sole discretion whether I do give information, and if I do, what that information is.

I may also compile statistics showing information obtained from this source to assess the level of service I provide, but not in a way that could identify you or any other person.

If a dispute is not settled, then I hope you will agree to attempt to resolve it by engaging in good faith with me in a process of mediation or arbitration.

If you are in any way dissatisfied about how I process your personal data, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. I would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

31. Retention period

Except as otherwise mentioned in this privacy notice, I keep your personal data only for as long as required :
· to provide you with the services you have requested
· to comply with other law, including for the period demanded by our tax authorities
· to support a claim or defence in court

32. Compliance with the law

This privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).

33. Review of this privacy policy

I shall update this privacy notice from time to time as necessary.