1) OUR CORE PRINCIPLES REGARDING USER PRIVACY AND DATA PROTECTION
Your privacy is very important to us. We have a few fundamental principles that we follow:
- We don’t ask you for personal information unless we truly need it.
- We have a duty of care to protect your personal information.
- We will never sell, rent or otherwise distribute or make public your personal information.
2) RELEVANT LEGISLATION
This website, like other elements of our online marketing, is designed to comply with the following national and international legislation with regards to data protection and user privacy:
- UK Data Protection Act 1988 (DPA)
- EU Data Protection Directive 1995 (DPD)
- EU General Data Protection Regulation 2018 (GDPR)
3) PERSONAL INFORMATION THAT THIS WEBSITE COLLECTS AND WHY WE COLLECT IT
This website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor (see section 6 below).
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.
3.2 Contact forms and email links
Should you choose to contact us using the contact form on our Contact page or via an email link, none of the data that you supply will be stored by this website or processed by any of the third party data processors defined in section 6.0. Instead the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.
3.3 Booking data
This website uses the WooCommerce e-commerce plug-in to manage workshop bookings. This long-established plug-in is very commonly used on WordPress stores across the internet.
When you book a workshop or other session via our website, your name, address and other contact information submitted at checkout is stored on the site so that we have a record of your order, and can send you email notifications relating to that order. Data submitted at checkout is not used for any other purpose.
The payment for your transaction takes place on Paypal’s website, not ours, and we neither store nor have access to your card or bank details.
We retain booking data for a period of 5 years for accounting purposes.
3.4 Email newsletter
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third party data processor (see section 6 below). The email address that you submit will not be stored within this website’s own database or in any of our internal computer systems.
Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the MailChimp database, you will receive periodic marketing emails from us.
4) HOW WE STORE YOUR PERSONAL INFORMATION
As detailed in section 3.3 above, if you book an event via this website some personal information will be stored within this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is build on (WordPress). In the near future we aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. We are committed to keeping it as a high priority and will implement it on this website as soon as we are able to.
5) ABOUT THIS WEBSITE’S SERVER
This website is hosted by TSOHOST (a member of Paragon Internet Group) within a secure UK data centre. This privately owned Tier 3+ 2N UK Data Centre uses the latest technology to deliver the highest reliability, security and performance. 3m perimeter fencing, 25+ CCTV cameras, 24×7 personnel and electronic access control systems, safeguards our data hall from unauthorised access.
6) OUR THIRD PARTY DATA PROCESSORS
We use a number of third parties to process personal data on our behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2. All of these third parties are based in the USA and are EU-US Privacy Shield compliant.
7) DATA BREACHES
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
8) WHO ARE WE?
The owner of this website is Kathryn Ellis, Central School of Massage, 2 St Mary’s Road, Leamington Spa, Warwickshire, CV31 1DB, UK.
9) HOW TO ACCESS MOVE OR DELETE YOUR PERSONAL DATA
If you would like further information about what personal data about you is stored on the site, if you would like to move or delete your data, please contact: email@example.com.
Last updated 09/05/18.