PRIVACY POLICY

INTRODUCTION

The General Data Protection Regulations (GDPR) come into effect in May 2018.

This legislation replaces the current data privacy law, giving more rights to you as an individual and more obligations to organisations that hold and process your personal data.

One of the rights is a right to be informed, which means I have to give you even more information than I do now about the way in which I use, share and store your personal information.

This means that I am publishing a new privacy notice so you can access this information, along with information about the increased rights you have in relation to the information I hold on you and the legal basis on which I am using it.

This new privacy notice will be published on my website.

 

I respect your privacy and am determined to protect your personal data. The purpose of this privacy notice is to inform you as to how I look after your personal data when you visit my website (regardless of where you visit it from). I’ll also tell you about your privacy rights and how the data protection law protects you.

WHO I AM AND IMPORTANT INFORMATION 

 

What is the purpose of this privacy notice?

 

This privacy notice aims to give you information on how I collect and process your personal data through your use of this website, including any data you may provide through this website when you sign up to my newsletter.

 

This website is not intended for children and I do not knowingly collect data relating to children.

 

You must read this privacy notice together with any other privacy notice I may provide on specific occasions when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data. This privacy notice supplements the other notices and is not intended to override them.

 

DATA CONTROLLER

 

Laura Fellows is the controller and responsible for your personal data (collectively referred to as "I", "me" or "my" in this privacy notice). My contact details are thesystemsvault@gmail.com, 07478 216107, 52 Totnes Drive, Cramlington, Northumberland, NE23 1PN.

 

THIRD-PARTY LINKS OUTSIDE OF OUR CONTROL

 

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. I do not control these third-party websites and am not responsible for their privacy statements.

 

When you leave my website, I encourage you to read the privacy notice of every website you visit.

THE PERSONAL DATA I COLLECT ABOUT YOU

 

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

I may collect, use, store and transfer different kinds of personal data about you which I have grouped together follows:

 

  • Identity Data includes first name/last name/ username/marital status/ title/date of birth/gender.

  • Contact Data includes billing address/delivery address/email address/ telephone numbers.

 

I 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, I may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if I combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, I treat the combined data as personal data which will be used in accordance with this privacy notice.

 

I do not collect any 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, information about your health and genetic and biometric data). Nor do I collect any information about criminal convictions and offences.

 

IF YOU FAIL TO PROVIDE PERSONAL DATA

 

Where I need to collect your 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 the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, I may have to cancel a product or service you have with me, but we will notify you if this is the case at the time.

 

HOW I COLLECT YOUR PERSONAL DATA

 

I use different methods to collect data from and about you including through:

 

  • Directly. You may give me your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • Apply for our products or services;

    • Subscribe to my service or publications;

    • Request marketing to be sent to you.

 

HOW I USE YOUR PERSONAL DATA

 

I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:

 

  • Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

  • Legitimate Interest means the interest of our business in conducting and managing my business to enable me to give you the best service/product and the most secure experience. I make sure we consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for our legitimate interests. I do not use your personal data for activities where our interests are overridden by the impact on you (unless I have your consent or are otherwise required or permitted to by law).

 

  • Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that I am subject to.

 

MARKETING

 

I strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. I will get your express opt-in consent before I share your personal data with any company outside The Systems Vault (part of Laura Fellows VA) group of companies for marketing purposes. I use a third-party provider, MailerLite, to deliver my monthly e-newsletters. I gather statistics around email opening and clicks using industry standard technologies including clear gifs to help me monitor and improve my e-newsletter. For more information, please see MailerLite’s privacy notice.

 

PROMOTIONAL OFFERS FROM ME

 

I may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what I think you may want or need, or what may be of interest to you. This is how I decide which products, services and offers may be relevant for you.

 

You will receive marketing communications from me if you have requested information from me or purchased goods or services from me and, in each case, you have not opted out of receiving that marketing.

 

OPTING OUT

 

You can ask me or third-parties to stop sending you marketing messages at any time by emailing thesystemsvault@gmail.com at any time.

 

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to me as a result of a product/service purchase, product or service experience or other transactions.

 

COOKIES

 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies I use, please see my cookie policy.

 

CHANGE OF PURPOSE

 

I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I 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 email Laura Fellows at thesystemsvault@gmail.com.

 

If I need to use your personal data for an unrelated purpose, I will notify you and I will explain the legal basis which allows us to do so.

 

Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

WIX

We use a third-party service, Wix, to publish our blog, and some of our conference microsites. These sites are hosted at wix.com. We use a standard Wix service to collect anonymous information about users' activity on the site, for example, the number of users viewing pages on the site, to monitor and report on the effectiveness of the site and help us improve it. Wix requires visitors that want to post a comment to enter a name and email address. For more information about how Wix processes data, please see their privacy notice.

 

WHOM I SHARE YOUR PERSONAL DATA WITH

 

I may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

 

  • Internal Third Parties

  • External Third Parties Service

    • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

    • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

  • Third parties to whom I may choose to sell, transfer, or merge parts of my business or my assets. Alternatively, I may seek to acquire other businesses or merge with them. If a change happens to my business, then the new owners may use your personal data in the same way as set out in this privacy notice.

 

I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow my 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 my instructions.

INTERNATIONAL TRANSFERS

 

I share your personal data within the group. This will involve transferring your data outside the European Economic Area (EEA).

 

A few of my external third parties 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 I transfer your personal data out of the EEA, I ensure a similar degree of protection is afforded to it by implementing safeguards:

 

  • PIA Risk Assessments are undertaken, and third-parties only used if low risk is ascertained.

 

Please contact me if you want further information on the specific mechanism used by me when transferring your personal data out of the EEA.

 

DATA SECURITY

 

I 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, I limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on my instructions and they are subject to a duty of confidentiality.

 

I 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 I am legally required to do so.

 

DATA RETENTION

 

I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.

 

Details of retention periods for different aspects of your personal data are available in my retention policy which you can request from me by email info@laurafellowsva.co.uk.

 

In some circumstances you can ask me to delete your data: see YOUR LEGAL RIGHTS below for further information.

 

In some circumstances, I may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case I may use this information indefinitely without further notice to you.

 

YOUR LEGAL RIGHTS

 

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

 

  • The right to request a copy of the personal data which I hold about you;

  • The right to request that I correct any personal data if it is found to be inaccurate or out of date;

  • The right to request your personal data is erased where it is no longer necessary to retain such data;

  • The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;

  • The right to request that I provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where my processing is based on consent or is necessary for the performance of our contract with you or where I process your data by automated means);

  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;

  • The right to object to my processing of personal data, where applicable i.e. where processing is based on my legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

 

If you wish to exercise any of the rights set out above, please contact info@laurafellowsva.co.uk

 

NO FEE REQUIRED – WITH SOME EXCEPTIONS

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.

 

WHAT I MAY NEED FROM YOU

 

I may need to request specific information from you to help me 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. I may also contact you to ask you for further information in relation to your request to speed up our response.

 

TIME LIMIT TO RESPOND

 

I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.

 

CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM ME OF CHANGES

 

This version was last updated on 1st July 2019.

 

From 25th May 2018 there will be changes in data protection laws and I will then be able to respond to some of your requests (for example, a request for the transfer of your personal data). I am still working towards getting my systems ready for some of these changes.

 

Please keep me informed if your personal data changes during your relationship with me. It is important that the personal data I hold about you is accurate and current.

 

QUERIES, REQUESTS OR CONCERNS

 

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and me, please in the first instance contact Laura Fellows info@laurafellowsva.co.uk

 

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.

INFORMATION ABOUT OUR USE OF COOKIES

 

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

 

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer, if you agree. Cookies contain information that is transferred to your computer’s hard drive.

 

We use the following cookies:

 

STRICTLY NECESSARY COOKIES

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

 

ANALYTICAL / PERFORMANCE COOKIES

They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works. For example, by ensuring that users are finding what they are looking for easily.

 

FUNCTIONALITY COOKIES

These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by your name and remember your preferences (for example, your choice of language or region).

 

TARGETING COOKIES

These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

 

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical / performance cookies or targeting cookies.

 

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

ACCEPTABLE USE POLICY

This Acceptable Use Policy sets out the terms between you and us under which you may access our website www.laurafellowsva.co.uk (our site). This Acceptable Use Policy applies to all users of, and visitors to, our site.

 

Your use of our site means that you accept, and agree to abide by, all the policies in this Acceptable Use Policy, which supplement our Terms and Conditions of Website.

 

www.thesystemsvault.co.uk is a site operated by Laura Fellows VA (we or us). We are registered in England and Wales and we have our registered office at 52 Totnes Drive, Cramlington, NE23 1PN.

 

PROHIBITED USES

 

You may use our site only for lawful purposes. You may not use our site:

 

  • In any way that breaches any applicable local, national or international law or regulation.

  • In any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect.

  • For the purpose of harming or attempting to harm minors in any way.

  • To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards (see below).

  • To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).

  • To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

 

You also agree:

 

  • Not to reproduce, duplicate, copy or re-sell any part of our site in contravention of the provision of our terms of website use.

  • Not to access without authority, interfere with, damage or disrupt:

    • Any part of our site;

    • Any equipment or network on which our site is stored;

    • Any software used in the provision of our site; or

    • Any equipment or network or software owned or used by any third party.

 

INTERACTIVE SERVICES

 

We may from time to time provide interactive services on our site, including, without limitation:

 

  • Chat rooms

  • Bulletin boards

 

Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).

 

We will do our best to assess any possible risks for users (and in particular, for children) from third parties when they use any interactive service provided on our site, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on our site, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.

 

The use of any of our interactive services by a minor is subject to the consent of their parent or guardian. We advise parents who permit their children to use an interactive service that it is important that they communicate with their children about their safety online, as moderation is not foolproof. Minors who are using any interactive service should be made aware of the potential risks to them.

 

Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.

 

CONTENT STANDARDS

 

These Content Standards apply to any and all material which you contribute to our site (contributions), and to any interactive services associated with it.

 

You must comply with the spirit and the letter of the following standards. The standards apply to each part of any contribution as well as to its whole.

 

Contributions must:

 

  • Be accurate (where they state facts).

  • Be genuinely held (where they state opinions).

  • Comply with applicable law in the UK and in any country from which they are posted.

 

Contributions must not:

 

  • Contain any material which is defamatory of any person.

  • Contain any material which is obscene, offensive, hateful or inflammatory.

  • Promote sexually explicit material.

  • Promote violence.

  • Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.

  • Infringe any copyright, database right or trade mark of any other person.

  • Be likely to deceive any person.

  • Be made in breach of any legal duty owned to a third party, such as a contractual duty or a duty of confidence.

  • Promote any illegal activity.

  • Be threatening, abusing or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety.

  • Be likely to harass, upset, embarrass, alarm or annoy any other person.

  • Be used to impersonate any person, or to misrepresent your identity or affiliation with any person.

  • Give the impression that they emanate from us, if this is not the case.

  • Advocate, promote or assist any unlawful act such as (by way of example only) copyright infringement or computer misuse.

 

SUSPENSION AND TERMINATION

 

We will determine, in our discretion, whether there has been a breach of this Acceptable Use Policy through your use of our site. When a breach of this policy has occurred, we may take such action as we deem appropriate.

 

Failure to comply with this Acceptable Use Policy constitutes a material breach of the terms of use upon which you are permitted to use our site, and may result in our taking all or any of the following actions:

 

  • Immediate, temporary or permanent withdrawal of your right to use our site.

  • Immediate, temporary or permanent removal of any posting or material uploaded by you to our site.

  • Issue of a warning to you.

  • Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.

  • Further legal action against you.

  • Disclosure of such information to law enforcement authorities as we reasonably feel is necessary.

 

We exclude liability for actions taken in response to breaches of this Acceptable Use Policy. The responses described in this policy are not limited, and we may take any other action we reasonably deem appropriate.

 

CHANGES TO THE ACCEPTABLE USE POLICY

 

We may revise this Acceptable Use Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are legally binding on you. Some of the provisions contained in this Acceptable Use Policy may also be superseded by provisions or notices published elsewhere on our site.

© 2019 by The Systems Vault