PRIVACY POLICY

(Last updated 25th June 2021)

1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and individual customers.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.

1.4    In this policy, "we", "us" and "our" refer to Giovanna Caracciolo. For more information about us, see Section 14.

2. Credit

2.1    This document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).

3. What personal data we collect

3.1 In this Section 3 we have set out the general categories of personal data that we process.

3.2    We may process data enabling us to get in touch with you ("contact data"). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer.

3.4    We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details The source of the transaction data is you and/or our payment services provider.

3.5    We may process information contained in or relating to any communication that you send to us or that we send to you ("communication data"). The communication 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.

3.6    We may process data about your use of our website and services ("usage data"). 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.

4. Purpose of processing and legal basis

When you conduct a transaction on our website, as part of the process, we collect personal information you give us (as described above). Your personal information will be used for the specific reasons stated below only.

4.1    In this Section 4, we have set out the purposes for which we may process personal data and the legal bases of the processing.

4.2    Operations - We may process your personal data for the purposes of providing our services, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

4.3    Publications - We may process account data (such as feedback) for the purposes of publishing such data on our website and elsewhere through our services in accordance with your express instructions. The legal basis for this processing is our legitimate interests, namely the publication of content in the ordinary course of our operations.

4.4    Relationships and communications - We may process contact data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, and individual customers, the maintenance of relationships, and the proper administration of our website, services and business.

4.5    Direct marketing - We may process contact data, and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.

4.6    Research and analysis - We may process usage data and/or transaction data for the purposes of researching and analysing the use of our website and services, as well as researching and analysing other interactions with our business. The legal basis for this processing is our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

4.7    Record keeping - We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.

4.8    Security - We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

4.9    Insurance and risk management - We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

4.10  Legal claims - We may process your personal data 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.

4.11  Legal compliance and vital interests - We may also process 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.

5. Storing your personal data and providing your personal data to others

5.1 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.

5.2    Your personal data held in our website database will be stored on the servers of our hosting services providers. Our website is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall. 

5.4    Financial transactions relating to our website and services may be 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. All direct payment gateways offered by Wix.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.

5.5    In addition to the specific disclosures of personal data set out in this Section 5, 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.

6. International transfers of your personal data

6.1    In this Section 6, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and/or EU data protection law.

6.2    We may transfer your personal data from the European Economic Area (EEA) to the UK and process that personal data in the UK for the purposes set out in this policy during any period with respect to which the UK is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law; and we may transfer your personal data from the UK to the EEA and process that personal data in the EEA for the purposes set out in this policy during any period with respect to which EEA states are not treated as third countries under UK data protection law or benefit from adequacy regulations under UK data protection law.

7. Retaining and deleting personal data

7.1    This Section 7 sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

7.2    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.

7.3    We will retain your personal data as follows:

(a)    contact data will be retained for a minimum period of 7 years following the date of the most recent contact between you and us, and for a maximum period of 10 years following that date;

(b)    transaction data will be retained for a minimum period of 7 years following the date of the transaction, and for a maximum period of 10 years following that date;

(c)     communication data will be retained for a minimum period of 7 years  following the date of the communication in question, and for a maximum period of 10 years following that date;

(d)    usage data will be retained for 7 years following the date of collection; and

7.4    Notwithstanding the other provisions of this Section 7, 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.

8. Your rights

8.1   In this Section 8, we have listed the rights that you have under data protection law.

8.2    Your principal rights under data protection law are:

(a)    the right to access - you can ask for copies of your personal data;

(b)    the right to rectification - you can ask us to rectify inaccurate personal data and to complete incomplete personal data;

(c)     the right to erasure - you can ask us to erase your personal data;

(d)    the right to restrict processing - you can ask us to restrict the processing of your personal data;

(e)    the right to object to processing - you can object to the processing of your personal data;

(f)     the right to data portability - you can ask that we transfer your personal data to another organisation or to you;

(g)    the right to complain to a supervisory authority - you can complain about our processing of your personal data; and

(h)    the right to withdraw consent - to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.

8.3    These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visiting [https://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/].

8.4    You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.

9. About cookies

9.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

9.2    Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

9.3    Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

10. Cookies that we use

10.1  We use cookies for the following purposes:

(a)    authentication - we use cookies to identify you when you visit our website and as you navigate our website,

(b)    personalisation - we use cookies to store information about your preferences and to personalise our website for you;

(c)     security - we use cookies as an element of the security measures used to protect our website and services generally;

(d)    advertising - we use cookies to help us to display advertisements that will be relevant to you

(e)    analysis - we use cookies to help us to analyse the use and performance of our website and services; and

(f)     cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally

 

Examples of cookies used by our hosting provider WIX.com are:

XSRF-TOKEN / hs / svSession / SSR-caching / wixCIDX / wix_browser_sess / consent-policy / smSession / TS* / bSession / fedops.logger.sessionId / wixLanguage

:

11. Cookies used by our service providers

12. Managing cookies

11.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

11.2  We use Google Analytics. Google Analytics gathers information about the use of our website by means of cookies. The information gathered is used to create reports about the use of our website. You can find out more about Google's use of information by visiting https://www.google.com/policies/privacy/partners/ and you can review Google's privacy policy at https://policies.google.com/privacy.

12.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647 (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop (Firefox);

(c)     https://help.opera.com/en/latest/security-and-privacy/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and

(f)     https://support.microsoft.com/en-gb/help/4468242/microsoft-edge-browsing-data-and-privacy (Edge).

12.2  Blocking all cookies will have a negative impact upon the usability of many websites.

12.3  If you block cookies, you will not be able to use all the features on our website.

 

For further details on cookies please visit www.allaboutcookies.org where you can find comprehensive information on cookie restriction and blocking for a wide variety of browsers.

13. Amendments

13.1  We may update this policy from time to time by publishing a new version on our website.

13.2  You should check this page occasionally to ensure you are happy with any changes to this policy.

13.3  We may notify you of significant changes to this policy by email.

14. Our details

14.1  This website is owned and operated by Giovanna Caracciolo who is trading under the name Evolving Mindscape.

14.2  You can contact us:

(a)    using our website contact form;

(b)    by telephone, on the contact number published on our website; or

(c)     by email, using the email address published on our website.