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Last updated: 24 June 2023
1. ABOUT THIS PRIVACY POLICY
1.1 The website www.worrybowl.org (the Site) is operated by The Positive Motherhood Project Limited ("we", "us", "our"), a company incorporated in England and Wales under company number 1313486. Our registered office is at Britannia House, Caerphilly Business Park, Van Road, Caerphilly, CF83 3GG.
1.2 We are committed to protecting your privacy and complying with our data protection obligations under the Data Protection Act 2018 (the DPA 2018), the UK General Data Protection Regulation 2016/679 (the UK GDPR) and any other applicable UK legislation (together, Data Protection Law).
1.3 When you interact with us or use the Site, we act as the data controller of your data. This means that we are responsible for processing your personal data and deciding how to use it. This privacy policy explains the types of personal data we may collect about you when you interact with us, why we collect it, what we use it for and what rights you have over that data. Personal data is any information about an identifiable person. Processing is anything we do with your personal data, including using, storing, sharing and deleting it.
1.4 This policy was last updated on the date shown at the top. We may change this policy at any time by posting an updated version on the Site and will make reasonable efforts to bring any material changes to your attention. You may wish to check it before using the Site as any changes will be effective from the date that they are made.
2.CONTACT INFORMATION
2.1 If you have any concerns or would like further information about our use of data or this policy in general, you can contact Anghard Davies on support@worrybowl.org.
3.WHAT INFORMATION DO WE COLLECT?
3.1 We collect, store and use the types of personal data set out in the table at the end of this policy.
4.HOW WILL WE USE YOUR PERSONAL DATA?
4.1 We will use your personal data for the purposes set out in the table at the end of this policy.
5.HOW DO WE SHARE YOUR PERSONAL DATA?
5.1 When we share personal data, we do so under Data Protection Law. We may share specific personal data, where necessary, with employees, contractors, consultants or advisers, to facilitate sales and for general commercial purposes. In addition, where necessary, your personal data may be shared:
5.2 We may also provide third parties with aggregated but anonymised information and analytics about our customers. Before we do so, we will make sure that it does not identify you.
6.THIRD-PARTY LINKS
6.1 This Site contains links to other websites over which we have no control. We are not responsible for and do not review or endorse the privacy policies or practices of other sites which you choose to access from this Site. We encourage you to review the privacy policies of those other sites, so you can understand how they collect, use and share your personal information.
7.YOUR RIGHTS
7.1 We respect your privacy rights and will respond to requests for access or control over information about you under Data Protection Law. We may require you to verify your identity before we take any action.
7.2 Depending on the reason we have your data, you have a right to:
7.2.1 access the personal information we hold about you (commonly known as subject access);
7.2.2 request that we correct or complete personal information we hold about you that is inaccurate or incomplete;
7.2.3 request that we erase your data in some circumstances or object to our processing it;
7.2.4 restrict how we use your personal information in certain circumstances;
7.2.5 request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services; and
7.2.6 where we have asked for your consent to process your data, to withdraw this consent.
7.3 These rights are limited in some situations under Data Protection Law – for example; we can demonstrate that we are under a legal obligation to process your data.
7.4 If you wish to exercise any of these rights, please contact us using the details above.
7.5 Your right to object You have a right to object to our data processing and ask us to stop doing so. Suppose we are processing your data for direct marketing purposes (which includes profiling to the extent that it is related to such direct marketing) and object to this. In that case, we will stop processing your data immediately. Suppose our processing of your data is in the public interest or under our legitimate interests, and you object to this. In that case, we will stop processing your data unless we have compelling reasons that override your interests or use your information for the establishment, exercise or defence of legal claims.
7.6 We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns, you also have the right to complain to data protection authorities (in the UK, the Information Commissioner's Office). You can call the ICO on 0303 123 1113 or go to their website: https://ico.org.uk/make-a-complaint/).
8.DATA RETENTION
8.1 Your data will only be kept for as long as necessary for our purposes. Specific periods are set out in the table at the end of this policy.
9.DATA PROTECTION PRINCIPLES
9.1 We process your data under the following principles:
9.1.1 we process your data lawfully, fairly and in a transparent way;
9.1.2 we collect your data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which we collected it;
9.1.3 we only process personal data which is adequate, relevant and limited to what is necessary to achieve the goal for which it is processed;
9.1.4 we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;
9.1.5 we do not store personal data in a form that identifies you for any longer than is required for the processing; and
9.1.6 we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage.
9.2 When we ask for your data, we will tell you whether you are required by law or contract to provide it and what will happen if you do not provide the data.
9.3 Any request for consent to the processing of your data will be made directly to you and include information about why we require the personal data and what will be done with it.
10.WHAT IS OUR LAWFUL BASIS FOR PROCESSING?
10.1 We will only process personal data when we have a lawful basis for doing that processing. At the end of this policy, the table sets out the legal basis we rely on for each type of data we process.
10.2 We will choose one of the lawful bases in the UK GDPR to justify how we use your data. These are:
10.2.1 Consent: You have given consent to the processing of your data for one or more specific purposes.
10.2.2 Contract: The processing is necessary for a contract's performance or to take steps at your request before entering into a contract.
10.2.3 Legal obligation: We need to process your personal data to comply with a legal obligation.
10.2.4 Vital interests: The processing is necessary to protect the vital interests of you or another person.
10.2.5 Public interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of some official authority.
10.2.6 Legitimate interests: Processing is necessary for legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
11.ATTRIBUTION
11.1 This privacy policy was created using a template from MJM Virtual Solutions.
TABLE OF PERSONAL INFORMATION WE USE
The table below sets out detailed information about our purposes for processing, the basis for processing and the retention period for the personal data.
Name and contact details
To deliver your free training or purchases to you
To send you to order updates
For fraud prevention and detection
To contact you with information, newsletters and marketing materials about our products and services
Performance of contract
Compliance with a legal obligation
Consent
For three years since you gave consent, or until you withdraw the consent if earlier
Payment information
To take payment and give refunds
For fraud prevention and detection
Performance of contract
Compliance with a legal obligation
For six years since you last logged on to the Site
Contact history
To provide customer service and support
To train our staff
For six years since you last logged on to the Site
Browser, device and Site usage information
To improve the Site
To protect the Site against fraud
To set default options for you, such as language and currency
For three years since you last logged on to the Site
Responses to surveys, competitions and promotions
To run the survey, competition or promotion
For six years
Client comments and product reviews
To improve our products and services
Where relevant, to establish, exercise or defend legal claims
For six years
The information generated in the course of the use of our products and services
For internal research and development purposes
To improve and test the features and functions of our Site
For four years
Information collected through cookies and similar technologies
To conduct and store site usage analytics, statistical and trend analysis and market research
To generate customer profiles to facilitate marketing initiatives
For three years since you gave consent, or until you withdraw the consent if earlier
Limited Company Registration Number: 13163486
Britannia House, Caerphilly Business Park, Van Rd, Caerphilly CF83 3GG
support@worrybowl.org