This privacy notice provides you with details of how we collect and process your personal data.

Janine Coombes is the data controller and is responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice). We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the “Last Updated” date at the top of this policy and, in some cases, we may provide you with additional notice (such as by adding a statement to our website or by sending you a notification).

Our email address is janine@janinecoombes.co.uk

Our address is

23 Surbiton Business Centre

46 Victoria Road

Surbiton

Surrey

KT6 4JL

Collection of Information

Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you subscribe to a newsletter or email list, participate in an event, survey, contest or promotion, make a purchase, communicate with us via third-party social media sites, request customer support or otherwise communicate with us.

The types of information we may collect include your name, email address, password, postal address, phone number, gender, date of birth, occupation, payment information (such as your credit or debit card and billing address), contact preference or interest data, and any other information you choose to provide.

If you provide an email address to invite a friend to participate in the Services, we will collect that email address and use it to send your friend such an invitation.

Information We Collect Automatically

When you access or use our Services, we may automatically collect information about you, including: Log Information: We collect log information about your use of the Services, including your Internet Protocol (“IP”) address, web request, access times, pages viewed, web browser, links clicked and the page you visited before navigating to the Services.

Information Collected by Cookies

We and our service providers use various technologies to collect information, including cookies.

Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits.

For more information about cookies, and how to disable them, please see “Your Choices” below.

Advertising and Analytics Services Provided by Others

We may allow others to serve advertisements on our behalf across the Internet and to provide analytics services.

These entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information.

This information may be used by Janine Coombes and others to, among other things, analyse and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity.

For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance, please visit http://www.aboutads.info/choices.

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Your Choices

Account Information

You may view, correct or modify information at any time by emailing us at janine@janinecoombes.co.uk. If you wish to delete or deactivate your account, please email us at janine@janinecoombes.co.uk, but note that some information you provide through the Services may continue to be accessible (e.g., comments you submit through the Services) and that we may continue to store information about you as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

We need to make sure the information we hold about you is accurate and up to date, so let us know if at any time your personal information changes by emailing us at janine@janinecoombes.co.uk

We may have to share your personal data with third parties, for example;

  • Service providers who provide IT and system administration services, and service providers such as Mailchimp who help manage our data.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

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.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies.

Promotional Communications

In general, we’ll only send you marketing communications if you’ve given us your consent. If you are a paying customer, we will be using your details to carry out contractual obligations and to make you aware of any other services we think you might be interested in.

You may opt out of receiving promotional communications from us by following the instructions in those communications or by sending an email to janine@janinecoombes.co.uk. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

If you have any questions about this Privacy Policy, please contact us at janine@janinecoombes.co.uk.

Transferring data outside the EEA

Some of the third parties service providers we used are based outside the European Economic Area (EEA) e.g. Mailchimp. So their processing of your personal data will involve a transfer of data outside the EEA.

European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

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 implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; 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
  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

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.

Please email us at janine@janinecoombes.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

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.

Keeping your data

We will only keep 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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

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

Your rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of these rights, please email us atjanine@janinecoombes.co.uk.

You won’t be charged 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. We may 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 and keep you updated.

Sensitive Data

We don’t collect any sensitive data on you or any of our customers e.g. race or ethnicity, religious or philosophical beliefs, sexual orientation etc.

If you’re not happy

If you’re 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). I’d appreciate it if you would contact us first if you do have a complaint so that we can try to resolve it for you.

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