Privacy PolicyThis Privacy Policy sets out how we at forRunners Website and App collect, store and use information about you when you use or interact with our websites, http://forrunners.app and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 20th November 2022.

SUMMARY

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

FULL PRIVACY POLICY

OUR DETAILS

Data Controller

The data controller in respect of our websites is Alice Baquie. You can contact the data controller by emailing [email protected]

If you have any questions about this Privacy Policy, please contact the data controller.

INFORMATION WE COLLECT WHEN YOU VISIT OUR WEBSITES

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Web server log information

We use a third-party server to host our websites called Heroku, Kajabi & Shopify Inc, the privacy policy of which is available here: https://kajabi.com/policies/privacy  https://www.shopify.com/legal/privacy. Our website servers automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system. Our servers are located in the United States.

Use of website server log information for IT security purposes. 

We AND/OR our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, We do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our and a third party’s legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we and our third-party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.

Use of website server log information to analyse website use and improve our website. We use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.

We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.

 

Cookies and similar technologies 

Cookies are data files which are sent from a website to a browser to record information about users for various purposes. We use cookies and similar technologies on our website, including essential, functional, analytical

You can reject some or all of the cookies we use on or via our website by changing your browser settings but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org 

 

INFORMATION WE COLLECT WHEN YOU CONTACT US

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

Email Information

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

We use a third party email provider to store emails you send us. Our third-party email provider is Google. Their privacy policy is available here: https://policies.google.com/privacy

Contact Form

When you contact us using our contact form, we collect name, email address, phone number, web address, company name, IP address. If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry. 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence. 

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Messages you send us via our contact form will be stored in the European Economic Area on our third-party hosting OR email provider’s servers in the US. Our third-party email or hosting provider is Google. Their privacy policy is available here: https://policies.google.com/privacy 

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

We use third party contact form providers to store messages you send us (depending on which store and which category of user you are). Our contact form providers are Google, Kajabi, Klaviyo. 

forRunners Website and App:

3rd party privacy policies are available here: 

Google - https://policies.google.com/privacy  

Kajabi -  https://kajabi.com/policies/privacy 

Klavio - https://www.klaviyo.com/legal

Messages you send to us via our contact forms will be stored within and outside the European Economic Area on our contact form provider’s servers.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Phone

If in the rare instance you contact us by phone, we collect your phone number and any information provide to us during your conversation with us. We do not record phone calls.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondenc

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so) 

Postal enquiry

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

INFORMATION WE COLLECT WHEN YOU INTERACT WITH ONE OF OUR WEBSITES 

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

E Newsletters

When you sign up for our e-newsletter on our website or opt to receive from us by entering your name and email address and clicking subscribe. We collect Name and Email address, Product you are in

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).

 

Consent: You consent to us sending you our e-newsletter by signing up to receive it using the steps described above. Transfer and storage of your information

We use a third party service to send out our e-newsletters and administer our mailing lists including Klaviyo. 

 

Their privacy policy is available here https://www.klaviyo.com/privacy

 

Information you submit to subscribe for our e-newsletter will be stored outside the European Economic Area on our servers in US. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

 

Use of web beacons in emails

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.

For more information about our third party mailing list provider and their use of web beacons, please see their privacy policies which are available here https://www.klaviyo.com/privacy

 

Registering on our Websites

 

When you register and create an account on our websites, we collect the following information: Name, Email address IP Address and any other information you provide to us when you complete the registration form.

 

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

 

Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

 

Reason why necessary to perform a contract: creating an account on our website is necessary to allow you to access the goods and services you have purchased from us

 

OR

 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

 

Legitimate interest: registering and administering accounts on our website to access project management tasks and facilitate the running and operation of our business.

 

Transfer and storage of your information

Information you submit to us via the registration form on our website will be stored within the European Economic Area on our third party hosting provider’s servers in United States. Our third party hosting providers are Heroku, Kajabi & Shopify Inc, the privacy policy of which is available here: 

 https://kajabi.com/policies/privacy  https://www.shopify.com/legal/privacy.

 

INFORMATION WE COLLECT WHEN YOU PLACE AN ORDER 

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Information collected when you place an order

 

MANDATORY INFORMATION

 

When you place an order for goods or services on our website, we collect your name, email address, billing address, shipping address, company name (if applicable), VAT number (if applicable), GST number (if applicable), phone number.

 

If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.

 

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

 

Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.

 

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to issue you with an invoice for the goods and services you purchase from us where you are VAT/GST registered and we require the mandatory information collected by our checkout form for this purpose. We also have a legal obligation to keep accounting records, including records of transactions

 

Processing your Payment

 

After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use Stripe.

Your payment will be processed by this 3rd party provider. Stripe collects, uses and processes your information, including payment information, in accordance with their privacy policies. You can access their privacy policy via the following link(s): https://stripe.com/au/privacy 

 

Transfer and storage of your information

 

Stripe.com is located in The United States. Information relating to the processing of your payment is stored within the European Economic Area on our third party payment processor’s servers.

 

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

 

Marketing Communications

 

At checkout you will have the option of receiving marketing communications from us.

 

Our goods and services

 

You can opt in to receiving marketing communications from us in relation to our goods and services by email, by ticking a box indicating that you would like to receive such communications.

 

We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.

 

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).

 

Legitimate interests: direct marketing and advertising our products and services.

Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.

 

Transfer and storage of your information

 

We use a third party service to administer our mailing list including Klaviyo. Their privacy policy is available here:

Information you submit to subscribe to our e-newsletter will be stored outside the European Economic Area on our third-party mailing list provider’s servers in the US. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

 

Use of web beacons in emails

 

We use technologies such as web beacons (small graphical files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click-through rates which our emails achieve. We will only use web beacons in our emails if you have consented to us doing so.

For more information about our third-party mailing list provider and their use of web beacons, please see their privacy policies which are available here: https://www.klaviyo.com/privacy

 

DISCLOSURE AND ADDITIONAL USES OF YOUR INFORMATION 

 

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

Disclosure of your information to service providers

 

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

 

Our third party service providers are located in the US. Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

 

We do not display the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

 

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

 

Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).

 

Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

 

Disclosure of your information to other third parties

 

We disclose your information to other third parties in specific circumstances, as set out below. Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://policies.google.com/privacy 

 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

 

Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout 

 

Transfer and storage of your information

 

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

 

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

 

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, and insurers,. Further information on each of these third parties is set out below.

 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

 

Legitimate interest: running and managing our business efficiently.

 

Advisors

 

Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and business advisors. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 

 

Legitimate interest: running and managing our business effectively.

 

AND/OR

 

Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation). 

Reason why necessary to perform a contract: we need to share your information with other companies in order to be able to meet our contractual obligations to you or to take steps at your request prior to entering a contract., for example because of the services or information you have requested.

 

We do not display the identities of all of the other third parties we may share information with by name for security and competitive reasons. If you would like further information about the identities of such third parties, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such third parties, for example).

 

Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential.

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). 

 

Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person in order to allow such a transaction to take place.

 

Disclosure and use of your information for legal reasons

 

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that a fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

 

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

 

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

 

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

 

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

 

In connection with a legal or potential legal dispute or proceedings

 

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

 

Legitimate interest(s): resolving disputes and potential disputes.

 

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering matters.

 

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation). 

 

Legal obligation(s): legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

 

HOW LONG WE RETAIN YOUR INFORMATION 

 

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods 

 

Server log information: we retain information on our server logs for 12 months.

Order information: when you place an order for goods and services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 6 further months after which point we will delete your information.

E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

 

Criteria for determining retention periods

 

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

 

HOW WE SECURE YOUR INFORMATION

Measures taken to secure your information

 

We take appropriate technical and organisational measures to secure your information and to protect it against the unauthorised or unlawful use and accidental loss or destruction, including:

 

Transmission of information to us by email

 

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

 

TRANSFERS OF YOUR INFORMATION OUTSIDE THE EUROPEAN ECONOMIC AREA 

 

Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

 

Server Log Information 

 

Information collected when you visit our website isn’t transferred outside of the EEA and stored on the servers of our third party hosting companies Kajabi & Shopify Inc, the privacy policy of which is available here: https://kajabi.com/policies/privacy  https://www.shopify.com/legal/privacy.

Country of storage: United States. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: our third party hosting provider has self-certified its compliance with the EU-U.S. Privacy Shield

 

Contact Form

 

Information you submit to us via our contact form is transferred outside the EEA and stored on our third party providers which is Klaviyo

Their privacy policies are available here: https://www.klaviyo.com/privacy

 

Country of storage: US. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: our third parties have self-certified their compliance with the EU-U.S. Privacy Shield

 

Email

 

Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers. Our third party email provider is: Google Inc. You can access their privacy policy here: https://policies.google.com/privacy 

 

Country of storage: US. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: our email has self-certified its compliance with the EU-U.S. Privacy Shield

 

E Newsletters

 

Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list providers are Klaviyo Their privacy policy is available here https://www.klaviyo.com/privacy

 

Country of storage: US. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Our Email has self-certified its compliance with the EU-U.S. Privacy Shield

 

Google Analytics

 

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://policies.google.com/privacy 

 

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en 



YOUR RIGHTS IN RELATION TO YOUR INFORMATION 

Your Rights

 

 

to request access to your information and information related to our use and processing of your information;

 

In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.

For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/ 

 

Further Information in relation to your personal data as an individual 

 

The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:

 

You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016R0679&from=en 

 

Verifying your identity where you request access to your information

 

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

 

How we verify your identity

 

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identify you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

 

YOUR RIGHT TO OBJECT TO THE PROCESSING OF YOUR INFORMATION FOR CERTAIN PURPOSES 

 

Your Right to Object

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to: 

 

 

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

 

SENSITIVE PERSONAL INFORMATION 

 

What is Sensitive Personal Information?

‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.

 

Our policy on Sensitive Personal Information

 

We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.

If however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.

 

CHANGES TO OUR PRIVACY POLICY 

 

We update and amend our Privacy Policy from time to time.

Minor Changes to our Privacy Policy

 

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

 

Major changes to our Privacy Policy or the purposes for which we process your information

 

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

 

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

 

ADDITIONAL INFORMATION 

Children’s Privacy

 

Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. These websites are not intended to solicit information of any kind from persons under the age of 18.

It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to our data controller Alice Baquie. You can contact the data controller by emailing [email protected]

 

California Do Not Track Disclosures

 

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org

We respond to Do Not Track browser settings through the settings in our websites as administered on Shopify Inc. Kajabi and Heroku.