1.1We are committed to safeguarding the privacy of Studio Charley visitors and customers.
1.2This policy applies where we are acting as a data controller with respect to the personal data of Studio Charley visitors and customers; in other words, where we determine the purposes and means of the processing of that personal data.
1.4In this policy, "we", "us" and "our" refer to Studio Charley.[ For more information about us, see Section 13.]
2.1This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1In this Section 3 we have set out:
(a)the general categories of personal data that we may process;
(b)[in the case of personal data that we did not obtain directly from you, the source and specific categories of that data];
(c)the purposes for which we may process personal data; and
(d)the legal bases of the processing.
3.2We 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]. The source of the usage data is [our analytics tracking system]. This usage data may be processed [for the purposes of analysing the use of the website and services]. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3We may process [information contained in any enquiry you submit to us regarding goods and/or services] ("enquiry data"). 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 [consent].
3.4We may process [information relating to our customer relationships, including customer contact information] ("customer relationship data"). The customer relationship data may include [your name, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you. The customer relationship data may be processed [for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers]. The legal basis for this processing is our legitimate interests, namely [the proper management of our customer relationships.
3.5We may process [information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters] ("notification data"). The notification data may be processed [for the purposes of sending you the relevant notifications and/or newsletters]. The legal basis for this processing is consent.
3.6We may process [information contained in or relating to any communication that you send to us] ("correspondence data"). The 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 and record-keeping]. The legal basis for this processing is [our legitimate interests, namely [the proper administration of our website and business and communications with users]].
3.7In addition to the specific purposes for which we may process your personal data set out in this Section 3, 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.
3.8Please do not supply any other person's personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1We 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].
4.2Financial transactions relating to our website and products may be handled by our payment services providers, [PayPal or SumUp]. 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]. You can find information about the payment services providers' privacy policies and practices at https://www.paypal.com/uk/webapps/mpp/ua/privacy-full and https://sumup.co.uk/privacy/.
4.3In 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.]
5. International transfers of your personal data
5.1In this Section 5, we provide information about the circumstances in which your personal data may be transferred to [countries outside the European Economic Area (EEA)].
5.2The hosting facilities for our website are situated in United States of America, in Europe (including in Lithuania, Germany and Ukraine), in Israel, and in other jurisdictions as necessary for the proper delivery of Services. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework, a copy of which you can obtain from [https://www.privacyshield.gov/]
5.3You acknowledge that [personal data that you 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.
6. Retaining and deleting personal data
6.1This Section 6 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.
6.2Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3We will retain your personal data as follows:
6.4Notwithstanding 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.
7.1We may update this policy from time to time by publishing a new version on our website.
7.2You should check this page occasionally to ensure you are happy with any changes to this policy.
8. Your rights
8.1In this Section 8, 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.
8.2Your 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.
8.3In 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 exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims].
8.4In 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.
8.5You 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.
8.6You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.7You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.8To the extent that the legal basis for our processing of your personal data is:
(b)that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.9If 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. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.10To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.11You 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 8].
9. About cookies
10. Managing cookies
10.1Most 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:
(d)https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e)https://support.apple.com/kb/PH21411 (Safari); and
10.2Blocking all cookies will have a negative impact upon the usability of many websites.
10.3If you block cookies, you will not be able to use all the features on our website.
13. Our details
13.1This website is owned and operated by Charlotte McKenzie.
13.3Our principal place of business is at 254 Dereham Road, New Costessey, Norwich, Norfolk, NR5 0SN.
13.4You can contact us:
(a)[by post, to [the postal address given above]];
(b)[using our website contact form];
(c)[by telephone, on [the contact number published on our website]]; or
(d)[by email, using [the email address published on our website from time to time]].