The Secret Garden (“We”) are committed to protecting and respecting your privacy.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
Data controller– A controller determines the purposes and means of processing personal data.
Data processor– A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Categories of data: Personal data and special categories of personal data
Personal data– The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data –The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party– means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
- Who are we?
The Secret Garden is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: The Secret Garden, 14 THE CHILTERNS, HITCHIN SG4 9PP email@example.com 632499. For all data matters contact firstname.lastname@example.org.
If you use the booking system on our website to book a class, register for a class or make an enquiry about a class, the data controller for all personal data entered into the booking system will be held by the The Secret Garden Teacher with whom you are booking a class or workshop. Their privacy notice will be made available to you during the booking process.
- The purpose(s) of processing your personal data
We use your personal data for the following purposes:
- to enable us to provide goods and services to our customers and clients
- to promote our services
- to maintain our own accounts and records
- The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
- Personal data, which may include: personal details, family details, business activities of the person whose personal information we are processing, lifestyle and social circumstances, financial details, training details, education and employment details, goods and services
- Special categories of data, which may include: physical or mental health details
- What is our legal basis for processing your personal data?
a) Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
|Consent of the data subject;||If you subscribe to our newsletter you will be asked to opt in to provide your consent receive our newsletters by email. If you complete an enquiry form on our website you will be given the option to opt-in to our newsletter.|
|Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract||If you enrol on one of our training courses or make a purchase through our online shop we will process your data in order to supply the goods or services you have purchased. Any financial details you provide in order to make payment for a purchase will be processed by our third party payment processor Stripe Payments Europe Ltd. We have access to only partial financial details in order to maintain our accounts and records.|
|Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject||If you make an enquiry through our website we will process your data in order to respond to your enquiry. If you contact us by email we may keep a record of that correspondence.|
- Sharing your personal data
Your personal data will be treated as strictly confidential, and may only be shared only if and when required with business associates and other professional advisers, educators and examining bodies, family, associates and representatives of the person whose personal data we are processing, financial organisations, credit reference agencies, debt collection and tracing agencies, suppliers and service providers, The Secret Garden Teachers, persons making an enquiry or complaint, other companies in the same group.
- How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes and use the following criteriato determine how long to retain your personal data:
- for as long as a contract remains in place between you and us
- for as long as you remain subscribed to our newsletter
- if you make an enquiry we will keep your data for a period of 1 year from the date of your enquiry
- if you purchase products we will keep your data for a period of 1 year from the date of your order
- Providing us with your personal data
We require your personal data to enable us to respond to your enquiry and as it is a requirement necessary to enter into a contract.
- Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we 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 your lawful basis for processing the data;
- The right to request that we 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 the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the 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 the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
- Transfer of Data Abroad
We do not transfer personal data outside the EEA.
- Automated Decision Making
We do not use any form of automated decision making in our business.
- Further processing
- How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact The Secret Garden, 14 THE CHILTERNS, HITCHIN SG5 2HY, 01462 632499 email@example.com
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Officeon 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. Our ICO reference number is ZA356717.
(Last updated 17 May 2018)
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