1.1 We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
"Personal data" is defined in Article 4(1) of the GDPR:
"'personal data' means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person".
1.4 In this policy, "we", "us" and "our" refer to Anne-Marie Beare. [For more information about us, see Section 14.]
2.1 This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
3. The personal data that we collect
3.1 Our company is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.
3.1 In this Section 3 we have set out the general categories of personal data that we process [and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data].
3.2 We may process data enabling us to get in touch with you "contact data". The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers]. The source of the contact data is Anne-Marie Beare. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.]
3.3 We may process "account data". The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is Anne-Marie Beare / www.kernowcounselling.com, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider
3.4 We may process information contained in or relating to any communication that you send to us or that we send to you "communication data". The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
3.5 We may process data about your use of our website and services "usage data" The usage data may include [your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use]. The source of the usage data is [our analytics tracking system].
4. Purposes of processing and legal bases
4.1 In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.
4.2 Operations - We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is [our legitimate interests, namely [the proper administration of our website, services and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].
4.3 Relationships and communications - We may process [contact data, account data, transaction data and/or communication data] for [the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling]. The legal basis for this processing is [our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.
4.4 Research and analysis - We may process usage data and/or transaction datafor the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is consent OR our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
4.5 Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
4.6 Legal claims - We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure]. The legal basis for this processing is our legitimate interests, namely [the protection and assertion of our legal rights, your legal rights and the legal rights of others].
4.7 Legal compliance and vital interests - We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
5. Providing your personal data to others
5.1 We may disclose your personal data to our insurers and/or professional advisers / accountancy professions (including HMRC) insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice and fulfilling legal obligations.
5.2 Your personal data held in our website database OR Identify personal data category or categories will be stored on the servers of our hosting services providers www.wix.com / www.kernowcounselling.com .
5.5 In addition to the specific disclosures of personal data set out in this Section 5, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6. International transfers of your personal data
6.1 In this Section 6, we provide information about the circumstances in which your personal data may be transferred to [countries outside the United Kingdom and the European Economic Area (EEA)].
6.2 Wix can store site-visitors' data in a number of locations. Site-visitors ́ personal information may be stored in data centers located in the United States of America, Ireland, South Korea, Taiwan and Israel. We may use other jurisdictions as necessary for the proper delivery of our services and/or as may be required by law.
6.3 Wix is a global company that respects the laws of the jurisdictions it operates within. The processing of the User Customer Data may take place within the territory of the European Union, Israel or a third country, territory, or one or more specified sectors within that third country, of which, the European Commission has decided that it ensures an adequate level of protection (transfer on the basis of an adequacy decision).
6.4 Any transfer to a third country, outside the European Union, that does not ensure an adequate level of protection according to the European Commission, will be undertaken in accordance with the Standard Contractual Clauses (2010/87/EU) set out in Appendix 1 of the Wix Data Processing Agreement (DPA)
6.5 The security of sensitive data is of extreme importance to Wix and we are 100% committed to data protection. See all the security certifications received by Wix.com.
6.6 You acknowledge that [personal data that you submit for publication through our website or services] may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
7. Retaining and deleting personal data
7.1 This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 7 years following the date of the most recent contact between you and us, and for a maximum period of 7 years following that date;
(b) communication data will be retained for a minimum period of 7 years following the date of the communication in question, and for a maximum period of 7years following that date;
(c) usage data will be retained for 12 months following the date of collection; and
(d) data category will be retained for a minimum period of 7 years following the date of collection.
7.4 Notwithstanding the other provisions of this Section 7, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Your rights
8.1 In this Section 8, we have listed the rights that you have under data protection law.
8.2 Your principal rights under data protection law are:
(a) the right to access - you can ask for copies of your personal data;
(b) the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure - you can ask us to erase your personal data;
(d) the right to restrict processing - you can ask us to restrict the processing of your personal data;
(e) the right to object to processing - you can object to the processing of your personal data;
(f) the right to data portability - you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority - you can complain about our processing of your personal data; and
(h) the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
8.3 These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
8.4 You may exercise any of your rights in relation to your personal data [by written notice to us, using the contact details set out below].
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
Cookie Name - Purpose - Duration - Cookie Type
consent-policy - Used for cookie banner parameters -12 months - Essential
smSession - Used to identify logged in site members - Session - Essential
TS* - Used for security and anti-fraud reasons - Session - Essential
bSession - Used for system effectiveness measurement - 30 minutes - Essential
fedops.logger.sessionId - Used for stability/effectiveness measurement - 2 months - Essential
wixLanguage - Used on multilingual websites to save user language preference -12 months - Functional
XSRF-TOKEN - Used for security reasons - Session - Essential
hs - Used for security reasons - Session - Essential
svSession - Used in connection with user login - 2 years - Essential
SSR-caching - Used to indicate the system from which the site was rendered -1 minute - Essential
_wixCIDX - Used for system monitoring/debugging - 3 months - Essential
_wix_browser_sess - Used for system monitoring/debugging session - Essential
Taken from www.wix.com
11. Cookies used by our service providers
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you will not be able to use all the features on our website.
13.1 We may update this policy from time to time by publishing a new version on our website.
13.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
14. Our details
14.1 This website is owned and operated by Mrs Anne-Marie Beare.
14.3 Our principal place of business is at 76 St Georges Road, Hayle, Cornwall TR27 4AL.
14.4 You can contact us:
(a) by post at 76 St Georges Road, Hayle, Cornwall, TR27 4AL;
(b) using our website contact form;
(c) by telephone, on 07915 908464 or
(d) by email, using firstname.lastname@example.org.
15. Data protection officer
15.1 Our data protection officer's contact details are: Mrs Anne-Mari