Learn with Smartie Privacy Notice 24.05.18
What is the purpose of this document?
Learn with Smartie is committed to protecting the privacy and security of your personal information. This Privacy Notice describes how we collect and use personal information about you and applies to everyone whose personal data we process.
Learn with Smartie is run by Caroline Bowers as a sole trader. If you have any questions about this Notice, please call Caroline on 07866 602074, e-mail her at firstname.lastname@example.org or write to her at Oak Farm, Maidensgrove, Henley-on- Thames, Oxfordshire RG9 6EX.
This notice is not contractual and we may update it at any time. This version is effective from 25 May 2018.
Data protection principles
We must comply with the principles relating to processing of personal data set out in the GDPR which, in summary, state that personal data shall:
- be processed fairly and lawfully in a transparent manner;
- be collected for specific, explicit and legitimate purposes and not be processed in any manner which is incompatible with those purposes;
- be adequate, relevant and limited to what is necessary for that purpose;
- be accurate and kept up to date where necessary, with every reasonable step being taken to ensure that personal data are accurate, having regard to the processing purpose, and are erased or rectified without undue delay;
- be kept in a form which permits identification of data subjects for no longer than is necessary for that purpose;
- be kept secure, safe from unauthorised access, accidental loss, damage or destruction; and
- be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction of damage, using appropriate technical or organisational measures.
Our collection, use and transfer of your data
Parents and guardians
We collect the following personal data in relation to, and from, parents and guardians of children who attend our lessons and events: name, address, telephone number and e-mail address. In relation to pony parties, we may receive some of these details (about other parents) from the parent of the hosting child.
This information is used for our legitimate interests such as confirming bookings, circulating information about the lesson or event in advance, billing purposes and debt collection. We may also use this for circulating dates of future events and availability for Learn with Smartie Privacy Notice 24.05.18
lessons (see the “What’s on correspondence” section below), unless the individual tells us that they do not want to receive this information.
In order to prepare and conduct the equestrian activities, we collect names, ages and addresses of those children whose parents or guardians have enrolled their children for lessons, parties and events. This information is obtained from the parents of each child attending the session and is only used to order to prepare for and run the lesson or event – it is not used afterwards or given to any third parties.
We may take photographs during the sessions but these will not be used on marketing materials without the consent of the relevant child’s parent.
We also collect information about other people who may be interested in our business (such as people who might enrol their children in the future) or who may be able to help us (such as other instructors, vets, farriers and other suppliers). This data usually consists of their name, job title, organisation, address, e-mail address and telephone number, as well as other information from e-mail signatures and footers, and is usually provided directly from the individual, although we might get supplier information from their websites or directories.
This information may be used for the legitimate interest of communicating with you in relation to specific events that you might be interested in or matters that you might be able to assist with.
We also obtain information about people, such as name, contact details and anything included in the message, when people make an enquiry through our website.
We keep the details of any complaints for our legitimate interest in trying to improve our business.
Organisations that may see your data
Our banks, accountants and insurers are also entitled to obtain specific data on request as part of our compliance checks and legal obligations, although they rarely need specific personal data. Our solicitors may see your personal data in relation to any potential or actual legal claim. These parties are subject to confidentiality obligations.
Our IT support and website hosting providers have access to all data on our systems to provide their services to us for legitimate interests. We use Gmail for our e-mail exchange, for which the data may be transferred to the US but there are adequate safeguards in place as its provider is self-certified to the Privacy Shield. We only allow our third-party service providers to use your personal data for specified purposes and in accordance with our instructions.
What’s on correspondence
As part of our legitimate business activities, we send out e-mails listing the open events we are holding and when parents can book their children in for lessons. We feel that this is an integral part of the business so that people know our availability and what is on offer, particularly during the school holidays. This is sent out to everyone on our database except those who have opted out of it.
You can opt out of this at any time by contacting us at email@example.com.
Special category personal data Learn with Smartie Privacy Notice 24.05.18
“Special categories” of particularly sensitive personal information, being data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for identifying people, health information and data concerning sex life or sexual orientation, require higher levels of protection.
We do not envisage collecting any special category data except where you need to give us health information about you or your child to keep you or them safe on our premises. If your child or a child attending a party you are organising has any medical conditions that might affect their ability to ride a pony, please let us know as soon as possible so that we can carry out a risk assessment and consider any additional measures we could take to help them. We will only hold this information where we have the consent of the relevant person or, in the case of a child, their parent or where this is necessary to protect the child’s vital interests and only use it for trying to ensure the individual’s safety.
We will not store or use information about any criminal convictions and offences.
Any personal data may be held and used for establishing, exercising or defending legal claims.
Use of our website
A cookie is a small file that asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Transferring information outside the EU
We use Gmail to send and receive e-mails. This is US based but there are adequate safeguards in place as they are self-certified to the Privacy Shield. Learn with Smartie Privacy Notice 24.05.18
This is the only situation in which we transfer personal data outside the EU.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us on 07866 602074 or at firstname.lastname@example.org. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to continue our professional relationship, depending on the specific data, why we need it and what risks the provision of it poses to your rights and freedoms. For example, if a supplier fails to provide contact details of its finance department or the details needed for payments, we may not be able to pay them.
Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal information without your knowledge or consent, where this is required or permitted by law.
You will not be subject to decisions based solely on automated processing which produces legal effects concerning you or similarly affects you.
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
How long will we use your information for?
We will hold the personal data of most parents and their children for up to seven years after their last lesson or event, but if there is any particular reason to retain data about a specific individual, we may retain it for up to seven years after the child reaches the age of 21.
We retain data about other individuals (such as suppliers) on an on-going basis but if you wish to be removed from this database, please contact us on 07866 602074 or at email@example.com.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Rights of access, correction, erasure, and restriction Learn with Smartie Privacy Notice 24.05.18
You have a number of rights under the GDPR:
- the right to access personal data we hold;
- the right to ask us to rectify or complete our records;
- the right to ask us to delete personal data;
- the right to object to us processing your personal data;
- the right to restrict our processing; and
- the right to ask us to transfer your personal data to another organisation.
These are not absolute rights and are subject to specific conditions and depend on our processing purposes. If you are interested in using any of these rights, please contact us on 07866 602074 or at firstname.lastname@example.org for more information. In most situations, you will not have to pay a fee to access your personal information (or to exercise any of the other rights).
Please inform us of any changes
It is important that the personal information we hold about you is accurate and current. Please contact us on 07866 602074 or at email@example.com if your personal information changes during your relationship with us so that we can update our records.
If you are unhappy with any aspect of our processing of your personal data, we ask that you contact us on 07866 602074 or at firstname.lastname@example.org first and discuss your concerns with us. If you are not satisfied with the outcome, you may lodge a complaint with the Information Commissioner’s Office, the UK supervisory authority for data protection issues.