Privacy Policy

I am Rachel Bolton, a sole trading business whose registered address is at 4 Bowden Hill, Ashburton, Devon TQ13 7EA. In this privacy notice, I will refer to myself as ‘me’, or 'I'. I am the Data Controller of the personal information I collect, hold and use about you, as explained in this notice.

You can get a hold of me in any of the following ways:

  1. by emailing me at info@rachelbolton.life; or
  2. by writing to me at 4 Bowden Hill, Ashburton, Devon TQ13 7EA.

I take the privacy, including the security of personal information I hold about you seriously. This privacy notice is designed to inform you about how I collect personal information about you and how I use that personal information. You should read this privacy notice carefully so that you know and can understand why and how I use the personal information I collect and hold about you.

I do not have a data protection officer, but if you have any questions about this privacy notice or issues arising from it, you should contact me (using the information set out previously), as I am responsible for matters relating to data protection within my organisation, including any matters in this privacy notice.

I may issue you with other privacy notices from time to time, including when I collect personal information from you. This privacy notice is intended to supplement these and does not override them.

I may update this privacy notice from time to time. This version was last updated on April 26, 2019.

Key definitions

The key terms that I use throughout this privacy notice are defined below, for ease:

Data Controller: under UK data protection law, this is the organisation or person responsible for deciding how personal information is collected and stored and how it is meed.

Data Processor: a Data Controller may appoint another organisation or person to carry out certain tasks in relation to the personal information on behalf of, and on the written instructions of the Data Controller. (This might be the hosting of a site containing personal data, for example, or providing an email-marketing service that facilitates mass distribution of marketing material to a Data Controller’s customer base.)

Personal Information: in this privacy notice, I refer to your personal data as ‘personal information’. ‘Personal information’ means any information from which a living individual can be identified. It does not apply to information that has been anonymised.

Special Information – certain very sensitive personal information requires extra protection under data protection law. Sensitive data includes information relating to health, racial and ethnic origin, political opinions, religiome and similar beliefs, trade union membership, sex life and sexual orientation and also includes genetic information and biometric information.

Details of personal information that I collect and hold about you

Set out below are the general categories and details of retention periods in relation to those categories and in each case the types of personal information that I collect, use and hold about you:

General CategoryTypes of Personal Data in that categoryRetention Periods
Identity informationThis is information relating to your identity such as your name (including any previous names and any titles that you use), gender, marital status and date of birthThis information is retained for the duration of our relationship, and then for an indeterminate amount of time thereafter, subject to the nature of our relationship
Contact informationThis is information relating to your contact details such as email address, addresses, telephone numbersThis information is retained for the duration of our relationship, and then for an indeterminate amount of time thereafter, subject to the nature of our relationship
Account informationThis is information relating to your account with me, if applicable (including username and password)This information is retained for the duration of our relationship, and then for an indeterminate amount of time thereafter, subject to the nature of our relationship
Payment informationThis is information relating to the methods by which you provide payment to me such as bank account details, credit or debit card details and details of any payments (including amounts and dates) that are made between meThis information is retained for the duration of our relationship, and then for an indeterminate amount of time thereafter, subject to the nature of our relationship
Transaction informationThis is information relating to transactions between me such as details of the goods, services and/or digital content provided to you and any returns detailsThis information is retained for the duration of our relationship, and then for an indeterminate amount of time thereafter, subject to the nature of our relationship
Survey informationThis is information that I have collected from you or that you have provided to me in respect of surveys and feedbackThis information is retained for the duration of our relationship, and then for an indeterminate amount of time thereafter, subject to the nature of our relationship
Marketing informationThis is information relating to your marketing and communications preferencesThis information is retained for the duration of our relationship, and then for an indeterminate amount of time thereafter, subject to the nature of our relationship

The types of personal data I collect about you may differ from person to person, depending on who you are and the relationship between us.

Details of special information that I collect and hold about you

Special information is explained above.

I can collect and hold the following types of special information about you:

  1. race;
  2. ethnic origin;
  3. politics;
  4. religion;
  5. trade union membership;
  6. genetics;
  7. biometrics;
  8. health;
  9. sex life;
  10. sexual orientation.

Where I do hold special information about you, then the retention periods are as follows:

Type of Special InformationRetention Periods
AllThis information is retained for the duration of our relationship, and then for an indeterminate amount of time thereafter, subject to the nature of our relationship

I do not collect information from you relating to criminal convictions or offences.

Details of how and why I use personal information

I am only able to use your personal information for certain legal reasons set out in data protection law. There are legal reasons under data protection law other than those listed below; but, in most cases, I will use your personal information for the following legal reasons:

  1. Contract Reason: this is in order to perform my obligations to you under a contract I have entered into with you;
  2. Legitimate Interests Reason: this is where the use of your personal information is necessary for my (or a third party’s) legitimate interests, so long as that legitimate interest does not override your fundamental rights, freedoms or interests;
  3. Legal Obligation Reason: this is where I have to use your personal information in order to perform a legal obligation by which I are bound; and
  4. Consent Reason: this is where you have given me your consent to use your personal information for a specific reason or specific reasons.

As explained above, there are more sensitive types of personal data, which require higher levels of protection. Where I process such sensitive types of personal data, I will usually do this in the following circumstances:

  1. I have your explicit consent;
  2. Where it is necessary in relation to legal claims;
  3. Where you have made the personal data public.

So that I am able to provide you with goods and services, I will need your personal information. If you do not provide me with the required personal information, I may be prevented from supplying the goods and services to you.

It is important that you keep your personal information up to date. If any of your personal information changes, please contact me as soon as possible to let me know. If you do not do this, then I may be prevented from supplying the goods and services to you (for example, if you move address and do not tell me, then your goods may be delivered to the wrong address).

Where I rely on consent for a specific purpose as the legal reason for processing your personal information, you have the right under data protection law to withdraw your consent at any time. If you do wish to withdraw your consent, please contact me using the details set out at the beginning of this notice. If I receive a request from you withdrawing your consent to a specific purpose, I will stop processing your personal information for that purpose, unless I have another legal reason for processing your personal information – in which case, I will confirm that reason to you.

I have explained below the different purposes for which I use your personal information and, in each case, the legal reason(s) allowing me to use your personal information. Please also note the following:

  1. if I use the Legitimate Interests Reason as the legal reason for which I can use your personal information, I have also explained what that legitimate interest is; and
  2. for some of the purposes, I may have listed more than one legal reason on which I can use your personal information, because the legal reason may be different in different circumstances. If you need confirmation of the specific legal reason that I rely on to use your personal data for that purpose, please contact me using the contact details set out at the start of this privacy notice.
PurposeLegal Reason(s) for me using the personal information
To enrol you as a customerContract Reason

Legitimate Interests Reason (in order to [offer you other goods, services and/or digital content which helps me to develop my business)

To process your order, which includes taking payment from you, advising you of any updates in relation to your order or any enforcement action against you to recover paymentContract Reason

Legitimate Interests Reason (in order to [recover money that you owe me])

To manage my contract with you and to notify you of any changesContract Reason

Legal Obligation Reason

To comply with audit and accounting mattersLegal Obligation Reason
For record keeping, [including in relation to any guarantees or warranties provided as part of the sale of goods, services and/or digital contentContract Reason

Legal Obligation Reason

To improve the goods, services, and/or digital content that I supplyLegitimate Interests Reason (in order to improve the goods, services, and/or digital content for future customers and to grow my business)
To recommend and send communications to you about goods, services, and/or digital content that you may be interested in. More details about marketing are set out in this noticeLegitimate Interests Reason (in order to grow my business

Consent Reason

To ensure the smooth running and correct operation of ny websiteLegitimate Interests Reason (to ensure my website runs correctly)
To understand how customers and visitors to my website use the website and interact with it via data analysisLegitimate Interests Reason (to improve and grow my business, including my website, and to understand my customer's needs, desires and requirements)

Sometimes I may anonymise personal information so that you can no longer be identified from it and use this for our own purposes. In addition, sometimes I may use some of your personal information together with other people’s personal information to give me statistical information for my own purposes. Because this is grouped together with other personal information and you are not identifiable from that combined data I am able to use this.

Under data protection laws, I can only use your personal information for the purposes I have told you about, unless I consider that the new purpose is compatible with the purpose(s) I told you about. If I want to use your personal information for a different purpose that I do not think is compatible with the purpose(s) I told you about, then I will contact you to explain this and what legal reason is in place to allow me to do this.

Details of how I collect personal information and special information

I usually collect Identity Information, Contact Information, Payment Information, Transaction Information, Survey Information, Marketing Information, Special Information; directly from you when you fill out a form, survey or questionnaire, purchase goods, services and/or digital content from me, contact me by email, telephone, in writing or otherwise. This includes the personal information that you provide to me when you subscribe to my mailing list enter a competition or survey.

I may also receive Website, Device and Technical Information automatically from technologies such as cookies that are installed on my website. To find out more about these please see my cookie policy, which is available here.

Details about who your Personal Information may be shared with

I may need to share your personal information with other organisations or people. These organisations include:

  1. Third parties who are not part of my group. These may include:
    1. Suppliers: such as IT support services, payment providers, administration providers, marketing agencies who are based in the United Kingdom and Italy;
    2. Government bodies and regulatory bodies: such as HMRC, fraud prevention agencies who are based in the United Kingdom;
    3. My advisors: such as lawyers, accountants, auditors, insurance companies who are based in the United Kingdom;
    4. My bankers who are based in the United Kingdom;
    5. Email platforms who are based in the United Kingdom and the United States;
  2. any organisations that propose to purchase my business and assets, in which case I may disclose your personal information to the potential purchaser.

Depending on the circumstances, the organisations or people who I share your personal information with will be acting as either Data Processors or Data Controllers. Where I share your personal information with a Data Processor, I will ensure that I have in place contracts that set out the responsibilities and obligations of me and them, including in respect of security of personal information.

I do not sell or trade any of the personal information that you have provided to me.

Details about transfers to countries outside of the EEA

If any transfer of personal information by me will mean that your personal information is transferred outside of the EEA, then I will ensure that safeguards are in place to ensure that a similar degree of protection is given to your personal information as is given to it within the EEA and that the transfer is made in compliance with data protection laws (including, where relevant, any exceptions to the general rules on transferring personal information outside of the EEA that are available to me – these are known as ‘derogations’ under data protection laws). I may need to transfer personal information outside of the EEA to the third parties listed above who may be located outside of the EEA.

The safeguards set out in data protection laws for transferring personal information outside of the EEA include:

  1. where the transfer is to a country or territory that the EU Commission has approved as ensuring an adequate level of protection;
  2. where personal information is transferred to another organisation within my group, under an agreement covering this situation, which is known as 'binding corporate rules';
  3. having in place a standard set of clauses that have been approved by the EU Commission;
  4. compliance with an approved code of conduct by a relevant data protection supervisory authority (in the UK, this is the Information Commissioner’s Office (ICO);
  5. certification with an approved certification mechanism;
  6. where the EU Commission has approved specific arrangements in respect of certain countries, such as the US Privacy Shield, in relation to organisations that have signed up to it in the USA.]

Details about how long I will hold your personal information

I will only hold your personal data for as long as is necessary. How long is necessary will depend upon the purposes for which I collected the personal information and whether I are under any legal obligation to keep the personal information (such as in relation to accounting or auditing records or for tax reasons). I may also need to keep personal information in case of any legal claims.

I have set out above the details of my retention periods for different types of data.

Automated decision making

‘Automated decision making’ is where a decision is automatically made without any human involvement. Under data protection laws, this includes profiling. ‘Profiling’ is the automated processing of personal data to evaluate or analyse certain personal aspects of a person (such as their behaviour, characteristics, interests and preferences).

Data protection laws place restrictions upon me if I carry out any automated decision making (including profiling) that produces a legal effect or similarly significant effect on you.

I do not carry out any automated decision making (including profiling) that produces a legal effect or similarly significant effect on you. If I do decide to do this then I will notify you and I will inform you of the legal reason I are able to do this.

Your rights under data protection law

Under data protection laws, you have certain rights in relation to your personal information, as follows:

  1. Right to request access: (this is often called ‘subject access’). This is the right to obtain from me a copy of the personal information that I hold about you. I may also provide you with certain other information in response to these requests to help you understand how your personal information is being meed.
  2. Right to correction: this is the right to request that any incorrect personal data is corrected and that any incomplete personal data is completed.
  3. Right to erasure: (this is often called the 'right to be forgotten'). This right only applies in certain circumstances. Where it does apply, you have the right to request me to erase all of your personal information.
  4. Right to restrict processing: this right only applies in certain circumstances. Where it does apply, you have the right to request me to restrict the processing of your personal information.
  5. Right to data portability: this right allows you to request me to transfer your personal information to someone else.
  6. Right to object: you have the right to object to me processing your personal information for direct marketing purposes. You also have the right to object to me processing personal information where my legal reason for doing so is the Legitimate Interests Reason and there is something about your particular situation that means that you want to object to me processing your personal information. In certain circumstances, you have the right to object to processing where such processing consists of profiling (including profiling for direct marketing).

In addition to the rights set out in this document, where I rely on consent as the legal reason for me using your personal information, you have the right to withdraw your consent.

If you want to exercise any of the above rights in relation to your personal information, please contact me using the details set out at the beginning of this notice. If you do make a request, then please note:

  1. I may need certain information from you so that I can verify your identity;
  2. I do not charge a fee for exercising your rights unless your request is unfounded or excessive; and
  3. if your request is unfounded or excessive, then I may decline to deal with your request.

Marketing

You may receive marketing from me about similar goods and services, where either you have consented to this, or I have another legal reason by which I can contact you for marketing purposes.

However, I will give you the opportunity to manage how or if I market to you. In any email that I send to you, I provide a link to either unsubscribe or opt out, or to change your marketing preferences. To change your marketing preferences, and/or to request that I stop processing your personal information for marketing purposes, you can always contact me on the details set out at the beginning of this notice.

If you do request that I stop marketing to you, this will not prevent me from sending communications to you that are not to do with marketing (for example in relation to goods, services or digital content that you have purchased from me).

I do not pass your personal information on to any third parties for marketing purposes.

Complaints

If you are unhappy about the way that I have handled or used your personal information, you have the right to complain to the UK supervisory authority for data protection, which is the Information Commissioner’s Office (ICO). Please do contact me in the first instance if you wish to raise any queries or make a complaint in respect of my handling or mee of your personal information, so that I have the opportunity to discuss this with you and to take steps to resolve the position. You can contact me using the details set out at the beginning of this privacy notice.

Third-party websites

My website may contain links to third-party website. If you click and follow those links, then these will take you to the third-party website. Those third-party websites may collect personal information from you and you will need to check their privacy notices to understand how your personal information is collected and used by them.