PRIVACY POLICY
Shelley Osman ~ The Connection Way is committed to safeguarding your privacy. Contact us if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.
By using this site or/and our services, you consent to the Processing of your Personal Data as described in the Privacy Policy.
Definitions
Personal Data - any information relating to an identified or identifiable natural person.
Processing - any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject - a natural person whose Personal Data is being processed.
Child - a natural person under 16 years of age.
We/us - Shelley Osman, data controller for www.shelleyosman.com
Data Protection Principles
We promise to follow the following data protection principles:
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Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
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Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
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Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
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Processing is limited within a time period. We will not store your personal data for longer than needed.
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We will do our best to ensure the accuracy of data.
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We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s Rights
The Data Subject has the following rights:
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Right to information – meaning you have the right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
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Right to erasure – meaning in certain circumstances you can request for your personal data to be erased from our records.
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Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
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Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
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Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
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Right to object to automated processing – meaning you have the right to object to automated processing, including profiling; and not to be subject to a decision based solely on automated processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
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Right to object to processing – meaning in certain cases you have the right to object to processing of your Personal Data, for example in the case of direct marketing.
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Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
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Right to withdraw consent – you have the right to withdraw any given consent for processing of your Personal Data.
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Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
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Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
If you wish to exercise any of the rights set out above, please email us at info@shelleyosman.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 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 your 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.
Data we gather
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Information you have provided us with
This might be customer data and communications data provided through sign-up, contact and registration forms on our website, by email, text, telephone, social media or in person. It may be your e-mail address, name, billing address, home address etc, as well as marketing preferences. It may also include Sensitive Data related to your health. -
Information automatically collected about you
This includes user and technical information that is automatically stored by cookies and other session tools. For example, your IP address, your purchase history, pages visited, links clicked etc. This information is used to analyse traffic to our site; to improve your customer experience eg helping us to provide relevant content; to maintain website backups; to customise online advertising. When you use our services or look at the contents of our website, your activities may be logged. -
Publicly available information
We might gather information about you that is publicly available.
We use your Personal Data in order to:
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provide our service to you. This includes, for example, registering your account; providing you with the services that you have requested; communicating and interacting with you in relation to those services; notifying you of changes to any services; providing you with promotional items at your request.
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enhance your customer experience;
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provide a service that is professional, relevant and safe.
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fulfil an obligation under law or contract;
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establish, pursue or defend any legal claims;
We use your Personal Data on legitimate ground and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
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to identify you;
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to provide you a service or to send/offer you a product;
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to ensure our service is delivered in a way that is professional, relevant and safe.
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to communicate either for sales or invoicing;
On the ground of legitimate interest we process your Personal Data for the following purposes:
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to keep records;
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to reply to communications;
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to send you personalized offers*;
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to administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of services offered;
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to administer our website:
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to develop our marketing strategy and grow our business;
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to establish, pursue or defend legal claims;
*As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history to be our legitimate interest.
With your consent we process your Personal Data for the following purposes:
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to send you newsletters and campaign offers;
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for other purposes we have asked your consent for;
With your explicit consent, we may process your Sensitive Data (related to your emotional and physical - maybe including sexual and reproductive health), so that we can provide the requested services in group and private sessions in a safe and relevant way.
We do not collect any Sensitive Data relating to your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership or genetic and biometric data. We do ot collect any information about criminal convictions and offences.
We process your Personal Data in order to fulfil obligations arising from law and /or use your Personal Data for options provided by law. Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We receive the right to anonymise Personal Data gatherer and to use any such data. We will use data outside the scope of this Policy only when it is anonymised.
We will retain 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. For tax purposes, the law requires us to retain basic customer information of six years after they stop being customers,
We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this we will ensure that:
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the link between purposes, context and nature of Personal Data is suitable for further processing;
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the further processing would not harm your interests and
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there would be appropriate safeguards for processing.
We will inform you of any further processing and purposes.
Who else can access your Personal Data
We do not share your Personal Data with strangers. We do not share your Personal data to third parties for marketing purposes.
We may in some cases share Personal Data about you with our trusted business partners in order to either make providing the service to you possible or to enhance your customer experience, We may share your data with:
Our processing partners
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Service providers who provide IT and system administration services - including WIX (website hosting), MailChimp (marketing platform).
Our business partners:
Other teachers and holistic therapists with whom we may occasionally offer joint services and events.
We only work with Processing partners who are able to ensure an adequate level of protection to your Personal Data.
We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
How we secure your data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks.
Even though we try our best we can not guarantee the security of information. However we promise to notify suitable authorities of data breaches. We will also notify you if there is a thread to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that you have to keep your username and password secret.
Children
We do not intend to collect or knowingly collect information from children. We do not target children with our services.
Contact Information
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Full name of legal entity: Shelley Osman, as Shelley Osman - The Connection Way
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Email address: info@shelleyosman.com
Please let me know by email if at any time your own contact data or other personal data changes, so that I can keep my records up-to-date.
Changes to this Privacy Policy
We reserve the right to make changes to this Privacy Policy.
Last modification was made 26/08/2020 to this Privacy Policy.