Privacy & Cookie Policy

Introduction

Jessica Riley is a “data controller”. This means that I am responsible for deciding how I hold and use personal information about you.
This privacy notice provides you with details of how I collect and process your personal data through your use of https://www.thecrownwings.com, including any information you may provide through my site when you purchase a product or service, sign up to my newsletter or take part in a prize draw or competition

This privacy notice provides you with certain information that must be provided to you under the UK-GDPR (the United Kingdom General Data Protection Regulation (the “GDPR”)).

Contact Details

My full details are

Full name of legal entity: Jessica Riley
Email address: jessica@thecrownwings.com

If you are not happy with any aspect of how I 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).

I would be grateful if you would contact me first if you do have a complaint so that I can try to resolve it for you.

It is very important that the information I hold about you is accurate and up to date. Please let me know if at any time your personal information changes by emailing me at jessica@thecrownwings.com.

What data I collect

Personal data means any information capable of identifying an individual. It does not include anonymised data.

I will collect, store, and use the following categories of personal information about you:

  • Communication Data that includes any communication that you send to me whether that be through the contact form on my website, through email, text, social media messaging, social media posting or any other communication that you send me.
  • Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details.
  • User Data that includes data about how you use my website and any online services together with any data that you post for publication on my website or through other online services.
  • Technical Data that includes data about your use of my website and online services such as your IP address, your login data, details about your browser, length of visit to pages on my website, page views and navigation paths, details about the number of times you use my website, time zone settings and other technology on the devices you use to access my website.
  • Marketing Data that includes data about your preferences in receiving marketing from me and our third parties and your communication preferences.

I do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. I do not collect any information about criminal convictions and offences.

How I collect your personal data

I collect data about you through a variety of different methods including:

  • Direct interactions: You may provide data by filling in forms on my site (or otherwise) or by communicating with me by post, phone, email or otherwise, including when you:
    – Order products or services;
    – Subscribe to my service or publications;
    – Request resources or marketing be sent to you;
    – Enter a competition, prize draw, promotion or survey; or
    – Give me feedback.
  • Automated technologies or interactions: As you use my site, I may automatically collect Technical Data about your equipment, browsing actions and usage patterns. I collect this data by using cookies, server logs and similar technologies.

I may also collect the following data from third parties:

  • Analytics providers such as Google (based outside the EU).
  • Advertising and social media networks such as Facebook (based outside the EU).
  • Search information providers such as Google (based outside the EU).
  • Technical, payment and delivery services such as data brokers or aggregators.

I may also receive data from publically available sources such as Companies House and the Electoral Register based inside the EU.

How I use your personal data

I will use the personal information we collect about you to:

  • Communication Data – This type of data is collected for the purpose of communicating with you, for record-keeping and for the establishment, pursuance or defence of legal claims. My lawful ground for this processing is my legitimate interests which in this case are to reply to communications sent to me, to keep records and to establish, pursue or defend legal claims.
  • Customer Data – This type of data is collected to supply the goods and/or services you have purchased and to keep records of such transactions. My lawful ground for this processing is the performance of a contract between you and me, and/or taking steps at your request to enter into such a contract.
  • User Data – This type of data is collected for the purpose of operating my website, to ensure relevant content is provided to you, to ensure the security of my website, to maintain back-ups of my website and/or databases and to enable publication and administration of my website, other online services and business. My lawful ground for this processing is my legitimate interests which in this case are to enable me to properly administer my website and my business.
  • Technical Data – This source of data is collected to analyse your use of my website and other online services, to administer and protect my business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of my advertising. My lawful ground for this processing is my legitimate interests which in this case are to enable me to properly administer my website and my business and to grow my business and to decide my marketing strategy.
  • Marketing Data – This source of data is collected to enable you to partake in my promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertising to you and measure or understand the effectiveness of this advertising. My lawful ground for this processing is my legitimate interests which in this case are to study how customers use my products/services, to develop them, to grow my business and to decide my marketing strategy.

I may also collect the above data to deliver relevant website content and advertisements to you (including social media or other display advertisements) and to measure or understand the effectiveness of the advertising I serve you. My lawful grounds for this processing is legitimate interest which is to grow my business.

I may also use such data to send other marketing communications to you. My lawful ground for this processing is either consent or legitimate interests (namely to grow and develop my business).

How I use particularly Sensitive Data

As mentioned above, I do not collect any Sensitive Data about you. However, where I am required to collect personal data by law, or under the terms of the contract between you and I, and you do not provide me with the data when requested, I may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide me with the requested data, I may have to cancel a product or service you have ordered but if I do, I will notify you at the time.

I will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email me at jessica@thecrownwings.com. In case I need to use your details for an unrelated new purpose I will let you know and explain the legal grounds for processing.

I may process your personal data without your knowledge or consent where this is required or permitted by law.

Tracking Cookies

What’s a cookie?

  • A “cookie” is a piece of information that is stored on your computer’s hard drive and which records how you move your way around a website so that, when you revisit that website, it can present tailored options based on the information stored about your last visit. Cookies can also be used to analyse traffic and for advertising and marketing purposes.
  • Cookies are used by nearly all websites and do not harm your system.
  • If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of my site.

How do I use cookies?

I use cookies to track your use of my website. This enables me to understand how you use the site and track any patterns with regards to how you are using my website. This helps me to develop and improve my website as well as products and / or services in response to what you might need or want.

Cookies are either:

  • Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or
  • Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. I use persistent cookies for Google Analytics.

Cookies can also be categorised as follows:

  • Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and/or service, and therefore cannot be turned off. Without these cookies, the services available to you on my website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
  • Performance cookies: These cookies enable me to monitor and improve the performance of my website. For example, they allow me to count visits, identify traffic sources and see which parts of the site are most popular.
  • Functionality cookies: These cookies allow my website to remember choices you make and provide enhanced features. For instance, I may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.

Links to other websites

My website may contain links to other websites of interest. However, once you have used these links to leave my site, you should note that I do not have any control over that other website. Therefore, I cannot be responsible for the protection and privacy of any information which 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.

Marketing communications

My lawful ground of processing your personal data to send you marketing communications is either your consent or my legitimate interests (namely to grow my business).

Under the Privacy and Electronic Communications Regulations, I may send you marketing communications from me if (i) you made a purchase or asked for information from me about my goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, I may send you marketing emails without your consent. However, you can still opt-out of receiving marketing emails from me at any time.

Before I share your personal data with any third party for their own marketing purposes I will get your express consent.

You can ask me or third parties to stop sending you marketing messages at any time by emailing me at jessica@thecrownwings.com at any time.

If you opt-out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions such as purchases, warranty, registrations etc.

Automated Decision-making

I do not carry out automated decision making or any type of automated profiling.

Data Sharing

Why might I share your personal information with third parties?

I may have to share your personal data with the parties set out below:

  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers.
  • Government bodies that require me to report processing activities.
  • Third parties to enforce or apply any contract with you or other agreements.
  • Third parties to whom I sell, transfer or merge parts of my business or my assets.

All my third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information in line with our policies. I do not allow our third-party service providers to use your personal data for their own purposes. I only permit them to process your personal data for specified purposes and in accordance with my instructions.

Transferring personal data to a country outside the UK

I may transfer any personal data I hold to a country outside the UK, provided that one of the following conditions applies:

  • (a) The country to which the personal data is transferred ensures an adequate level of protection for your rights and freedoms.
  • (b) You have given your consent.
  • (c) The transfer is necessary for one of the reasons set out in GDPR, including the performance of a contract between you and I, or to protect your vital interests.
  • (d) The transfer is legally required on important public interest grounds or for the establishment, exercise or defence of legal claims.
  • (e) The transfer is authorised by the relevant data protection authority where I have adduced adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of those rights.

Personal data I hold may also be processed by staff operating outside the UK who work for me or for one of my suppliers. That staff maybe engaged in, among other things, the fulfilment of contracts with you, the processing of payment details and the provision of support services.

I currently use the transfer data in the following ways:

  • I use https://www.mailchimp.com to send newsletters and email marketing, which is based in the USA.
  • I use Google Analytics to report on my website analytics, which is based in the USA.
  • I use Google Drive to store client documents which is based in the USA.
  • I use https://www.dropbox.com to store and back-up client documents and my website which is based in the USA.
  • I use https://www.lyricalhost.com to host and backup my website which is based in the UK.

Data Security

I 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. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

I 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.

Mobile device privacy

The following applies to my site when viewed on a mobile device:

  • When accessed with a mobile device, my site may collect information automatically, such as the type of mobile device you have, device identifiers and information about your use of the site. Regardless of the device you use to access the site, it will also collect the information you provide, as well as information about your interaction with the site and its content.
  • If location services are activated on your mobile device, my site may collect information about the location of your device. Your mobile network service providers may collect device-specific information, such as a device identifier, when you use my website. This information collected by your mobile network service will not be associated with your user account with me, or with your personally identifiable information.

Data Retention

How long will you use my information for?

I will only retain your personal data for as longa s necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for, I will look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes, the law requires me to keep basic information about my customers (including Contact, Identity, Financial and Transactional Data) for 6 years after they stop being customers.

In some circumstances, I may anonymise your personal data for research or statistical purposes in which case I may use this information indefinitely without further notice to you.

Your rights to access, correction, erasure and restriction

Under certain circumstances, by law, you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information I hold about you and to check that I am lawfully processing it.
  • Request correction of the personal information that I hold about you. This enables you to have any incomplete or inaccurate information I hold about you corrected.
  • Request erasure of your personal information. This enables you to ask me to delete or remove personal information where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where I am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where I am processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask me to suspend the processing of personal information about you, for example, if you want me to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.

If you want to review, verify, correct or request the erasure of your personal information, object to the processing of your personal data, or request that I transfer a copy of your personal information to another party, please contact me (Jesica Riley) in writing at jessica@thecrownwings.com.

You will no have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.

I try to respond to all legitimate requests within one month. Occasionally, it may take me longer than a month if your request is particularly complex, or if you have made several requests. In this case, I will notify you and keep you updated.

Right to withdraw consent

You have the right to withdraw your consent for processing your information at any time. To withdraw your consent, please contact me at jessica@thecrownwings.com. Once I have received notification that you have withdrawn your consent, I will no longer process your information and, subject to my retention policy, I will dispose of your personal data securely.

Policy amendments

I may update this privacy policy from time to time by posting a new version on my website.

You should check this page occasionally to ensure you are happy with any changes. I may also notify you of changes to our privacy policy by email if you have elected to receive these.

[Date last updated: 11th January 2021]