Privacy Policy
DATA PROTECTION AND RETENTION POLICY
The School of Self Love
Last Updated: 23 MAY 2018
IMPORTANT INFORMATION AND WHO WE ARE
We are The School of Self Love : A Daring And Mighty Company of Apt 10940, Chynoweth House, Trevissome Park, Truro TR4 8UN trading as The School of Self Love.
For the purposes of data protection legislation, we will be the “controller” or “data controller” of all Data held in respect of this Policy.
The School of Self Love (“we”/“us”/“our” etc) is committed to protecting the privacy of all personal data collected in the course of our business, this includes your data.
We will at all times ensure that the minimum amount of personal data is kept, and for no longer than necessary, for us to meet our document retention objectives and data protection obligations.
This Data Protection and Retention Policy sets out how we will collect and retain personal data in relation to our newsletter (known as ‘Your Weekly Love Note’) and any email communications in which we offer or promote products or services - both free and paid - which we deem to be relevant to the subject of self-love, personal and spiritual transformation.
This policy is an important part of our data protection compliance processes. It should be read alongside our other Data Protection and Retention Policies, which can be found on the School of Self Love website.
We will always comply with relevant Data Protection Legislation (including the Data Protection Act 1998 (“DPA”) and General Data Protection Regulation (“GDPR”) as applicable) when dealing with your personal data. Further details on the DPA and GDPR can be found at the Information Commissioner’s Office website (www.ico.gov.uk).
All breaches of this Policy should be reported to our Data Protection Administrator Katie Phillips at katie@theschoolofself.love, to whom all queries regarding this Policy should also be addressed.
WHAT DATA DO WE COLLECT?
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(i) Customer Data (Identity & Contact Data) that includes data relating to any purchases of goods and/or services such as your first name, last name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card 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.
(ii) 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.
(iii) Technical Data includes internet protocol (IP) address, browser type and version, login data, length of visits to pages on our website, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this 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.
(iv) Usage 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.
(v) 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.
(vi) 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).
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We only collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, photographs, information about your health and genetic and biometric data) if you voluntarily share it with us as part of a coaching programme you are enrolled in or are exploring enrolling in with The School of Self Love or if you voluntarily share it on one of our Facebook Pages (including private group, public group and business pages).
HOW WE COLLECT PERSONAL DATA
We use different methods to collect data from and about you including through:
1. Direct interaction. You may give us your Identity and Contact Data by filling in any opt-In subscription form from our site. You may also give us Special Data if you include this in a coaching preparation form, a complimentary call form or if you volunteer any information via any of our social media pages (including group, public and business Facebook pages, Instagram, Twitter, Linked-In and YouTube) or via personal email or text message to any member of the School of Self Love.
2. Automated technologies or interactions. As you interact with our website, we may automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
WHY WE COLLECT PERSONAL DATA
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
1. Purpose/Activity : To register you as a subscriber to the School of Self Love Community. When you voluntarily opt-in to our community (whether that be to get a free meditation, a free video training series, a free mini-course, a free audio training, or our newsletter) you get access to our Weekly Love Notes plus all email offers (both free and paid) which we deem to be of interest to our subscribers because they pertain to self-love, personal and spiritual transformation.
Type of data : (i) Identity (ii) Contact
Lawful basis for processing including basis of legitimate interest : Performance of contract with you ( to provide you with the ‘opt-in gift’ (i.e. a free meditation, a free video training series, a free mini-course, a free audio training) / to provide you with our Weekly Love Notes plus all email offers.
2. Purpose/Activity : To send you the School of Self Love newsletter (Love Note)
Type of data : (i) Identity (ii) Contact
Lawful basis for processing including basis of legitimate interest : Performance of contract with you ( to provide you with the newsletter)
3. Purpose/Activity : To manage our relationship with you, which will include notifying you about changes to our data retention and protection policy
Type of data: (i) Identity (ii) Contact
Lawful basis for processing including basis of legitimate interest :
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
4. Purpose/Activity : To administer and protect our business and newsletter (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data : (i) Identity (ii) Contact (iiI) Technical
Lawful basis for processing including basis of legitimate interest :
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
5. Purpose/Activity : To deliver relevant content to you and measure or understand the effectiveness of the content we serve to you
Type of data : (i) Identity (ii) Contact (iii) Technical (iv) Usage
Lawful basis for processing including basis of legitimate interest : Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
6. Purpose/Activity : To use data analytics to improve our newsletter, products/services, customer relationships and experiences
Type of data : (iv) Technical (v) Usage
Lawful basis for processing including basis of legitimate interest : Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
7. Purpose/Activity : To progress a potential coaching relationship with you when you complete the ‘Complimentary Call’ submission form
Type of data : i) Identity (ii) Contact (iii) Technical (iv) Usage
Lawful basis for processing including basis of legitimate interest : Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
8. Purpose/Activity : To progress an existing coaching relationship with you when you complete the ‘Coaching Preparation’ submission form
Type of data : i) Identity (ii) Contact (iii) Technical (iv) Usage
Lawful basis for processing including basis of legitimate interest : Performance of contract with you (Preparation for your next coaching session)
We do not do targeted marketing. Any recommendation of a third party in our newsletter or email correspondence with you is for our whole community. We do not target our recommendations at individuals.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
WHEN WILL WE SHARE YOUR DATA?
We may have to share your personal data with the parties set out below for the purposes set out above. Parties we may have to share your data with include:
(a) Mailchimp (view their privacy policy here https://mailchimp.com/legal/privacy/ )
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
THIRD PARTY LINKS
Our Emails and Newsletter 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.
INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA). Our subscribers do come from all over the globe but our Emails and Newsletter are created within the United Kingdom and all data connected with any correspondence from us is kept in the EU.
OPTING OUT
You can ask us to stop sending you communications at any time by clicking unsubscribe on our Newsletter or Email or by contacting us at any time.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, volunteers, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WE KEEP DATA FOR
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Our Data Protection Administrator will monitor and enable our process of identifying which records and information have met their required retention period and will supervise their destruction.
In general we will retain your data until you unsubscribe from our Community (the Newsletter or any email). Once you have unsubscribed we may retain your data for up to 6 months to ensure that your data has been deleted or anonymised in all locations.
We will delete or anonymise your data once you have unsubscribed.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of these rights, please contact us.
In particular, you have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly
used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
In addition, you have the right to take any complaints about how we process your personal data to the Information Commissioner:
Information Commissioner’s Office Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
0303 123 1113.
You can read more about your rights at:
If you wish to exercise any of the rights set out above, please email us at katie@theschoolofself.love
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
COOKIES
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For more information about the cookies we use, please see our cookie policy on our website.
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