We have created this privacy statement to demonstrate our current and continuing commitment to the privacy of personal information provided by those visiting and interacting with this website and the content provided on the site. We hold the privacy of your personal information in the highest regard. The following discloses our information gathering and dissemination practices for this website.
The website and its content is owned by Cindy Galvin Ltd. (“Company”, “we”, or “us”)(“Company”, “we”, or “us”). The term “you” refers to the user or viewer of www.cindygalvin.ltd (“Website”).
2. WHAT DATA DO WE COLLECT ABOUT YOU AND FOR WHAT PURPOSE?
When you visit our website, we collect personal information and also web site information, from you so that we can provide you with a positive experience when utilizing our Website and any content provided. We will only collect the minimum amount of information necessary for us to fulfill our obligation to you. We may collect:
* Personal Information You Choose to Provide
* Registration Information
* When you register for any of our products, services or newsletters you will provide us information about yourself.
* Credit Card Information
* If you choose to avail of our services, you may need to give personal information and authorisation to obtain information from various credit services. For example, you may need to provide the following information:
* Mailing address
* Email address
* Credit card number
* Name on credit card
* Credit card billing address
* Business and home phone number
* Email Information
Please note that the information above (“Personal Data”) that you are giving to us is voluntarily, and by you providing this information to us you are giving consent for us to use, collect and process this Personal Data. You are welcome to opt-out or request for us to delete your Personal Data at any point by contacting us at email@example.com or hitting the unsubscribe button/link.
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. Along with processing the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
If you choose not to provide us with certain Personal Data, you may not be able to participate in certain aspects of our Website or content.
Website Use Information
A. Anonymous Data Collection and Use
To maintain our Website’s high quality, we may use your IP address to help diagnose problems with our server and to administer the Website by identifying which areas of the Website are most heavily used, and to display content according to your preferences. Your IP address is the number assigned to computers connected to the Internet. This is essentially “traffic data” which cannot personally identify you but is helpful to us for marketing purposes and for improving our services. Traffic data collection does not follow a user’s activities on any other websites in any way. Anonymous traffic data may also be shared with business partners and advertisers on an aggregate basis.
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.
B. Use of “Cookies”
3. HOW DO WE USE THE INFORMATION YOU PROVIDE TO US?
We use personal information for purposes of providing the products and services you requested, to process your payment, prevent fraudulent transactions, statistical analysis, to monitor the use of the service, our marketing and promotional efforts and improve our content and service offerings, and customize our site’s content, layout, services and for other lawful purposes. These uses improve our site and better tailor it to meet your needs such as:
A. Contact You
We may contact you with information that you provide to us based on these lawful grounds for processing:
1. We may contact you if you give us your clear, unambiguous, affirmative consent to contact you.
2. We will contact you under our contractual obligation to deliver goods or services you purchase from us.
3. Legitimate Interest. We may contact you if we feel you have a legitimate interest in hearing from us. For example, if you sign up for a webinar, we may send you marketing emails based on the content of that webinar. You will always have the option to opt out of any of our emails
B. Process Payments
We will use the Personal Data you give to us in order to process your payment for the purchase of goods or services under a contract. We only use third party payment processors that take the utmost care in securing data and comply with the GDPR.
C. Targeted Social Media Advertisements
We may use the data you provide to us to run social media advertisements and / or create look-alike audiences for advertisements.
D. Shared with Third Parties
We may have to share your personal data with the parties set out below:
* Service providers who provide IT and system administration services.
* Professional advisers including lawyers, bankers, auditors and insurers
* Government bodies that require us to report processing activities.
* Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Occasionally, we may also use the information we collect to notify you about important changes to our Website, new services, and special offers we think you will find valuable. You may notify us at any time if you do not wish to receive these offers by clicking Unsubscribe at the bottom of all emails or by emailing us firstname.lastname@example.org.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
4. THIRD PARTY LINKS?
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
5. SHARING AND SELLING INFORMATION
We do not share, sell, lend or lease any of the information that uniquely identify a subscriber (such as email addresses or personal details) with anyone except to the extent it is necessary to process transactions or provide services that you have requested.
What About Legally Compelled Disclosure of Information?
We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights. We may also disclose account information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Service or to protect the safety of our users and the Public.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
* We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
* Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
* If we use US-based providers that are part of the EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
7. HOW CAN YOU ACCESS AND CORRECT YOUR INFORMATION?
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
If you wish to exercise any of the rights set out above, please email us at email@example.com.
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 or refuse to comply with your request in these circumstances.
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.
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.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
8. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
9. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
10. POLICY MODIFICATIONS
11. VISITORS' GDPR RIGHTS
If you are within the European Union, you are entitled to certain information and have certain rights under the General Data Protection Regulation. Those rights include:
We will retain the any information you choose to provide to us until the earlier of: (a) you asking us to delete the information, (b) our decision to cease using our existing data providers, or (c) the Company decides that the value in retaining the data is outweighed by the costs of retaining it.
You have the right to request access to your data that the Company stores and the rights to either rectify or erase your personal data.
You have the right to seek restrictions on the processing of your data.
You have the right to object to the processing of your data and the right to the portability of your data.
To the extent that you provided consent to the Company’s processing of your personal data, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based upon consent that occurred prior to your withdrawal of consent.
You have the right to lodge a complaint with a supervisory authority that has jurisdiction over issues related to the General Data Protection Regulation.
We require only the information that is reasonably required to enter into a contract with you. We will not require you to provide consent for any unnecessary processing as a condition of entering into a contract with us.
Cindy Galvin Ltd
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