I (Eve Menezes Cunningham) understand that I have a responsibility to protect and respect your privacy and look after your personal data.
I respect your privacy and am determined to protect your personal data. The purpose of this privacy notice is to inform you as to how I look after the personal data I collect from you. I’ll also tell you about your privacy rights and how the data protection legislation protects you.
1. WHO WE ARE AND IMPORTANT INFORMATION
I am an author, journalist, self-care coach, supervisor, psychosynthesis counsellor, yoga instructor and therapist, NLP Master Practitioner, Advanced EFT Practitioner and crystal coach. I was registered with the Information Commissioner’s Office for Data Protection from 2004-2019 and have been registered with the Data Protection Commission since moving to the Republic of Ireland in 2019.
The ‘We’ in this Privacy Notice includes others working with me (eg technical support people).
What is the purpose of this privacy notice?
This privacy notice aims to give you information about how we collect and process your personal data through your use of our website, including any personal data you may provide through the website when you sign up to our email list, download any free content, purchase a product or service, take part in a competition, or any other way in which you may provide us with your personal information.
Our website, products and services are not intended for use by individuals under the age of 13 years old and we do not knowingly collect personal data relating to children.
Please read this privacy notice carefully together with any other privacy statements we may provide from time to time when collecting or processing your personal data, so that you are fully aware of how and why we are using your personal data.
2. THE PERSONAL DATA WE COLLECT ABOUT YOU
We may process the following categories of personal data about you:
• Identity Data which may include first name/last name/username/marital status/title/date of birth/gender.
• Contact Data which may include billing address/delivery address/email address/telephone numbers.
• Payment Data which may include card details/bank details/third party payment details (such as PayPal).
• Health Data may include medical information collected during a one to one consultation.
• Usage Data includes your IP address and/or mobile device ID.
We may also collect, use and share aggregated data such as statistical or demographic data for any purpose and at our sole discretion. Aggregated data may be derived from your personal data but does not constitute personal data because it is anonymised. For example, we may aggregate usage data to calculate the percentage of users accessing a specific website feature. If we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data and will process it in accordance with this privacy notice.
If you fail to provide personal data
Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to terminate our contract with you, but we will notify you if this is the case at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect personal data from and about you including:
a. Directly. You may give us your identity, contact, payment or health data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Apply for or buy our products or services;
• Create an account on our website;
• Book an appointment;
• Attend a session;
• Download free content;
• Subscribe to our emails or publications;
• Request marketing to be sent to you.
Third-party links outside of our control
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to process your personal data. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Performance of a contract – this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Legitimate interests – this means our own interests in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• To comply with a legal or regulatory obligation – this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
• Consent – we sometimes process your personal data when we have obtained your express consent. For example, when we collect special category data (e.g. health data) and when you opt-in to direct marketing via email or text message.
You have the right to withdraw consent to marketing at any time by contacting us at email@example.com
5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so. Note that we may process your personal data under more than one lawful basis depending on the specific purpose for which we are using your personal data.
Please contact us at firstname.lastname@example.org if you would like more detail about the specific legal grounds we rely on to process your personal data where more than one ground has been set out in the table below.
|Purpose/activity||Category of personal data||Lawful basis for processing|
|To comply with tax and accounting laws||Identity data
|Comply with a legal or regulatory obligation|
|To provide our services||Identity data
Performance of a contract
|Direct marketing||Identity data
|To register you as a new customer||Identity data
|Performance of a contract|
From time to time we would like to send you details of new products, services, promotions, offers and general information about what we think might be of interest you.
We can only use your personal information to send you this information if we have your consent or if you are an existing customer and have not opted out of marketing.
By consenting to receive this information (by email and text), we will process your personal data in accordance with this privacy notice.
If you have provided your consent to receive marketing communications from us and you change your mind, you can change your preferences and unsubscribe at any time by unsubscribing from the relevant communication channel or by contacting us at email@example.com
If you choose not to receive this information, we will be unable to keep you informed of new content, products, services and promotions that may interest you.
We may send you communications such as those which relate to any service updates (e.g. appointment confirmations). We consider that we can lawfully send these communications to you as we have a legitimate interest to do so, namely, to effectively provide you with the best service we can.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product or service experience or other transactions.
Change of purpose
We will only use your personal data 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 you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org
If we need to use your personal data 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 data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. WHO WE SHARE YOUR PERSONAL DATA WITH
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.
External third party service providers:
• Google inc Google Analytics, based in the United States of America who provide data services.
• Mailchimp, based in the United States of America who provide email marketing services.
• PayPal and Woocommerce, based in the United States of America who provide payment services.
• Other add ons
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may also have to share personal data in order to:
• Meet any applicable law, regulation, legal process or enforceable governmental request.
• Enforce applicable policies, including investigation of potential violations.
• Detect, prevent, or otherwise address fraud, security or technical issues.
• Protect against harm to the rights, property or safety of our users, the public or to us and/or as required or permitted by law.
7. INTERNATIONAL TRANSFERS
When we share your personal data with third party service providers, this will involve transferring your personal data outside of the Republic of Ireland, United Kingdom and the European Economic Area (EEA). Whilst these countries will have data protection rules that differ from the EEA, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your personal data remains protected to the standards described in this privacy notice.
If you would like further information about who we share your personal information with, please contact us at email@example.com
8. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and will be subject to a duty of confidentiality.
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.
9. DATA RETENTION
We will keep your personal data for no longer than is necessary for the purposes for which it was obtained. The criteria for determining the duration for which we will retain your personal data is as follows:
1. We will retain your personal data in a form that permits identification only for as long as:
a. We maintain an ongoing relationship with you;
b. Your personal data is necessary in connection with the lawful purposes set out in this privacy notice for which we have a valid legal basis.
2. For the duration of:
a. any applicable limitation period under applicable law (i.e. any period during which any person could bring a legal claim against us in connection with your personal information, or to which your personal data may be relevant); or
b. an additional reasonable period following the end of such applicable limitation period.
3. If any relevant legal claims are brought, we may continue to process your personal data for such additional periods as are necessary in connection with that claim.
During the periods specified in paragraphs 2(a) and 2(b) above, we will restrict our processing of your personal data to the storage of, and maintaining the security of, that data, except to the extent that data needs to be reviewed in connection with any legal claim or obligation under applicable law.
After this period your personal data will be anonymised so that you are no longer identified or identifiable from such information, or securely deleted/destroyed.
We may retain personal data about you for statistical purposes. Where data is retained for statistical purposes it will always be anonymised, meaning that you will not be identifiable from that data.
For a list of all retention periods, please contact firstname.lastname@example.org In some circumstances you can ask us to delete your data: See Your Legal Rights below for further information.
10. YOUR LEGAL RIGHTS
You have the following rights with respect to your personal data:
• The right to request a copy of your personal data;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means;
• The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please contact us at email@example.com
Generally, you will not be required to pay a fee to exercise any of the above rights – with some exceptions. For example, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive.
What we may need from you
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.
Time limit to respond
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.
11. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was updated on 23/7/2020
Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and up to date.
12. QUERIES, REQUESTS OR CONCERNS
To exercise all relevant rights, queries or complaints in relation to this notice or any other data protection matter between you and us, please in the first instance contact us at firstname.lastname@example.org
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Data Protection Commission
What are cookies
Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.
Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.
When you use and access the Service, we may place a number of cookies files in your web browser.
- To enable certain functions of the Service
- To provide analytics
We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:
- Analytics cookies. We may use analytics cookies to track information how the Service is used so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, features or new functionality of the Service to see how our users react to them.
In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.
What are your choices regarding cookies
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
- For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050
- For the Internet Explorer web browser, please visit this page from Microsoft: http://support.microsoft.com/kb/278835
- For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
- For the Safari web browser, please visit this page from Apple: https://support.apple.com/kb/PH21411?locale=en_US
- For any other web browser, please visit your web browser’s official web pages.
Where can you find more information about cookies
You can learn more about cookies and the following third-party websites:
- AllAboutCookies: http://www.allaboutcookies.org/
- Network Advertising Initiative: http://www.networkadvertising.org/
Westport, Co Mayo, Republic of Ireland and, when travel’s possible again, London and Essex, UK.
(c) Eve Menezes Cunningham 2004-2020. All rights reserved.