1.0 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and customers. This means - where we determine the purposes and means of processing that personal data.
1.2 Our website incorporates a privacy control on our ‘shopping cart checkout’ which affects how we will process your personal data. This gives you the option to opt into our mailing list or not. If you check the box to opt in you are specifying you would like to receive direct email marketing from us by being added to the Lisa Lochhead Artistry and Design Mailing List
1.3 In this policy, "we", "us" and "our" refers to the website named ‘Lisa Lochhead’ and our company ‘Off the Shelf (Bristol) Ltd’. For more information about us, see Section 13.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
2.2 Usage Data - We may process data about your use of our website and services. 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 inbuilt analytics tracking system in our website provider. This usage data may be processed for the purposes of analysing the use of the website and our services. The legal basis for this processing is our legitimate interests, namely for monitoring and improving our website and services. Meaning we get to see what is working for our business on our website and what is not. This enables us to provide a better experience and service to you, our customers.
2.3 Notification Data - We process your name and email address when you sign up as a subscriber to our mailing list – these details that you provide to us to access this notification service make up your subscriber profile. The data we hold always includes your name and email address. And other fields such as your home address, birthday, telephone number can also be added by you should you decide to choose to fill in on those fields on your subscriber profile. The source of this data is directly given to us by you by opting into our mailing list either via the sign up form on the website, when making an online purchase or in person at an event. Your data may be processed for the purposes of providing our services to you and the most important one to us is so we can communicate with you about things that could be of interest to you. We just love to let you know what we are up too and how you can join in! The legal basis for this processing is consent.
2.4 Enquiry Data - We may process information contained in any enquiry you submit to us regarding products and/or services. The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is legitimate interests.
2.5 Transaction Data - We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website. This transaction data would normally include your contact details, your card details and the transaction details. The transaction data would be processed for the purpose of supplying the purchased products and services and keeping proper records of those transactions under our legal obligation. The legal basis for this processing is the performance of a contract between you and us, and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website, services and business.
2.6 Publication Data - We may process information that you share with us in the way of testimonials, photos and/or videos for publication on our website or through our services and social media. The information that is given for publication is for sharing support of our business and its values. The legal basis for this processing is with your consent. (We would never use any material where consent has not been expressly and freely given.)
2.6 Correspondence Data - We may process information contained in or relating to any communication that you send to us. This correspondence 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. The correspondence data may be processed for the purposes of communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business in communicating with you.
2.7 We may process any of your personal data identified in this policy 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.
2.8 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.9 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of 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.
2.10 Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
This section concerns any time we are likely to share your personal data with anyone else to run our business and/or provide services to you.
3.1 We may disclose your name, address and contact details to our postal and shipping services to fulfil a contract with you. This means if you buy a product, piece of artwork or a type of service that requires us to post or ship to you. These include
3.2 Financial transactions relating to our website and services are handled by our payment services providers. We will share transaction data with our payment services providers 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.
Our payment service providers are:
· Through our website Stripe. To find information about the payment services providers' privacy policies and practices Click Here
· By direct invoicing or in person events - Square Up. You can find information about the payment services providers' privacy policies and practices by Clicking Here
3.3 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.4 In addition to the specific disclosures of personal data set out in this Section 4, 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.
4 International transfers of your personal data
In this section about International data transfers of your personal data we are providing you the information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA)].
Our providers of services that run our business are based in the USA. The European Commission has made an "adequacy decision" with respect to the data protection laws of this country. Transfers to this country need to protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, in regards to this country the appropriate safeguards are a certified compliance with a EU-U.S or a Swiss-U.S Privacy Shield Framework. Our providers are compliant with these safeguards and here are their details.
4.3 You acknowledge that any personal data that you may 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.
5. Retaining and deleting personal data
Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.1 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 that is collected for.
5.2 We will retain your personal data as follows:
(a) transaction data when you make a purchase through our website, via invoicing or in person card payment processing will be retained for a period of 6 years following the end of the company’s last financial year to comply with our legal obligation under HMRC
b) Your subscriber details on our mailing list database will only be held for as long as you consent to receive our marketing and communications. You can withdraw your consent at any time by clicking on Unsubscribe at the bottom of any email we send to you or here by clicking Unsubscribe
5.4 Notwithstanding the other provisions of this Section 6, 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.
6. Security of personal data
6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
6.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
6.3 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
6.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
The General Data Protection Regulation is new and the ICO is still issuing new bits of guidance about how businesses should follow it. That means that:
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
9. Your rights
In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. You can see a lot more information on them, if you are interested, on the UK Information Commissioner’s Office website. Click Here
9.1 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
9.2 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
9.3 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
9.4 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
9.5 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
9.6 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
9.7 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes – which we don’t use). If you make such an objection, we will cease to process your personal data for this purpose.
9.8 To the extent that the legal basis for our processing of your personal data is:
(a) legitimate interests
(b) that the processing is necessary for the performance of a contract with you OR in order to take steps at your request prior to entering into a contract.
9.9 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. If you are UK based you have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk).
9.10 When you subscribe to our mailing list the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. You can do this by clicking ‘Unsubscribe’ at the bottom of any email we send you. Withdrawal will not affect the lawfulness of processing before the withdrawal.
9.11 You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section 9
10. Third party websites
Our website can include hyperlinks to, and details of, third party websites of businesses. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
11. Updating information
It is important that your personal data is up to date and accurate. So please do update any personal information that we hold that needs to be corrected or updated. You can do this by 'Updating Your Preferences' at the bottom of any email notification you have received from me from my Mailing List. Contact firstname.lastname@example.org if you are having difficulty.
12. About cookies
13. Our details
19.1 This website is owned and operated by Off the Shelf (Bristol) Ltd.
19.2 We are registered in [England and Wales] under registration number 07500061, and our registered office is at 7 Badger Crescent, Whitchurch, Shrosphire, SY13 4JL.
19.3 Our principal place of business is as above.
19.4 You can contact us:
(a) by post, to the postal address given above.
(d) by email, using the email address email@example.com.
14. Data protection registration
With respect to our obligations under data protection law please contact Lisa Lochhead by email on firstname.lastname@example.org