PRIVACY POLICY

1. Introduction

We are committed to safeguarding the privacy of our website visitors, service users, and individual clients.

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.

We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

In this policy, "we", "us" and "our" refer to Emma Shoesmith. For more information about us, see section 13.

2. The personal data that we collect

In this section we set out the general categories of personal data that we process.

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 social media account identifiers. The source of the contact data is you.

We may process your website user account data ("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 you, although some elements of the account data may be generated by our website.

We may process information relating to transactions, including purchases of goods and services, that you enter into with us or through our website ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and our payment services provider.

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 exchanged via email, our website contact form, or social media platforms, together with metadata such as the date, time, device, or account used to send the message. The source of this data is the communication between you and us using those platforms, although some elements of the data may be generated by those platforms.

We may process information that you provide when engaging with our services ("engagement data"). The engagement data may include your responses to surveys or feedback forms, your participation in group coaching discussions, and your contributions in online forums or chat groups linked to our services. The source of the engagement data is your direct interaction with our services and platforms.

We may process data about your use of our website and services ("usage data"). The usage data may include information about your browser, network, and device, web pages you visited prior to coming to this website, and your IP address. This information may also include details about your use of this website, including clicks, internal links, pages visited, scrolling, searches, and timestamps. The source of the usage data is our website analytics provider, Squarespace, to learn about site traffic and activity.

3. Purposes of processing and legal bases

In this section, we set out the purposes for which we may process personal data and the legal bases of the processing.

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.
Relationships and communications: We may process contact data, account data, transaction data and communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, via our website, social media platforms, 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 clients and client personnel, the maintenance of relationships, and the proper administration of our website, services and business.
Direct marketing: We may process contact data, account data and transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, and social media platforms for marketing-related purposes. The legal basis for this processing is consent.
Research and analysis: We may process usage data and transaction data for 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 our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.
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.
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.

4. Providing your personal data to others

Your personal data held in our website database will be stored on the servers of our hosting services provider, SquareSpace.

We may disclose categories of personal data in section 2 that we process to our suppliers or subcontractors insofar as reasonably necessary for the proper administration of our website, services and business.

Financial transactions relating to our website and services are handled by our payment services provider, Stripe. We will share transaction data with Stripe only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about Stripe’s privacy policies and practices at https://stripe.com/gb/privacy.

In addition to the specific disclosures of personal data set out in this section, 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.

5. International privacy laws

If you are visiting our services or website from outside the United Kingdom, please be aware that you are sending information (including personal data) to the United Kingdom where our business is registered.

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.

6. Retaining and deleting personal data

We may retain your Personal Data as long as you are using our services. You may contact us to delete your data. However, we may retain personal data for an additional period as is permitted or required under applicable laws. Even if we delete your personal data it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.

7. Your rights

In this section, we list your rights under data protection law.

Your principal rights under data protection law are:

the right to access: you can ask for copies of your personal data.
the right to rectification: you can ask us to rectify inaccurate personal data and to complete incomplete personal data.
the right to erasure: you can ask us to erase your personal data.
the right to restrict processing: you can ask us to restrict the processing of your personal data.
the right to object to processing: you can object to the processing of your personal data.
the right to data portability: you can ask that we transfer your personal data to another organisation or to you.
the right to complain to a supervisory authority: you can complain about our processing of your personal data.
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.

These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting the Information Commissioner’s Office (ICO) website.

You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out in section 13.

8. About cookies

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.

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.

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.

9. Cookies that we use

We use cookies for the following purposes:

authentication and status: we use cookies to identify you when you visit our website and as you navigate our website, and to help us determine if you are logged into our website.
shopping cart: we use cookies to maintain the state of your shopping cart as you navigate our website.
personalisation: we use cookies to store information about your preferences and to personalise our website for you.
security: we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally.
analysis: we use cookies to help us to analyse the use and performance of our website and services.
cookie consent: we use cookies to store your preferences in relation to the use of cookies more generally.

10. Cookies used by our service providers

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

We use Google Analytics, which gathers information about the use of our website and uses cookies for this purpose. We use the information gathered by Google Analytics to create reports about the use of our website. You can find out more about Google's use of information by visiting https://policies.google.com/technologies/partner-sites and you can review Google's privacy policy at https://policies.google.com/privacy. The cookies used by Google Analytics are named _ga and _ga+container-id.

11. Managing cookies

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 obtain up-to-date information about managing cookies via your browser’s website (e.g. Chrome, Firefox, Safari, Edge, etc).

It’s worth noting that blocking all cookies will have a negative impact on the usability of many websites.

If you block cookies, you will not be able to use all the features on our website.

12. Amendments

We may update this policy from time to time by publishing a new version on our website. Any updates to this policy will be posted to our website with a change to the "Updated" date at the top of this policy.

You should check this page occasionally to ensure you are happy with any changes to this policy, and especially before you provide any personal data. Your continued use of our services and business following the effectiveness of any updates to this policy constitutes acceptance of those updates. If any updates to this policy is not acceptable to you, you should cease accessing, browsing and otherwise using our services or business.