Privacy Policy

This Privacy Policy sets out how we, Corinne Hamak Ltd, collect, store and use information about you when you use or interact with our website, https://www.corinnehamak.com/ (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 24th May 2018.

 

Contents

  • Summary
  • Our details
  • Information we collect when you visit our website
  • Information we collect when you contact us
  • Information we collect when you interact with our website
  • Information we collect when you place an order on our website
  • Our use of automated decision-making and profiling
  • How we collect or obtain information about you from third parties
  • Disclosure and additional uses of your information
  • How long we retain your information
  • How we secure your information
  • Transfers of your information outside the European Economic Area
  • Your rights in relation to your information
  • Your right to object to the processing of your information for certain purposes
  • Sensitive Personal Information
  • Changes to our Privacy Policy
  • Children’s Privacy
  • California Do Not Track Disclosures
  • Copyright, credit and logo

 

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

  • Data controller: Cotswold Web Limited
  • How we collect or obtain information about you:
    • when you provide it to us (e.g. by contacting us, placing an order on our website and by signing up to our newsletter.
    • from your use of our website, using cookies and similar technologies, and
    • occasionally, from third parties.

 

  • Information we collect: name, contact details, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable), and VAT number (if applicable).

 

  • How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to advertise our goods and services, to analyse your use of our website, and in connection with our legal rights and obligations.

 

  • Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, and where required by law or to enforce our legal rights.

 

  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No

 

  • How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.

 

  • How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.

 

  • Use of cookies and similar technologies: we use cookies on our website including essential, functional and analytical cookies. For more information, please visit our cookies policy: https://www.corinnehamak.com/cookies-policy

 

  • Transfers of your information outside the European Economic Area: in certain circumstances we transfer your information outside of the European Economic Area, including to the United States of America. Where we do so, we will ensure appropriate safeguards are in place, including, for example, that the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield.

 

  • Use of automated decision making and profiling: we do not use automated decision making or profiling.

 

  • Your rights in relation to your information
    • to access your information and to receive information about its use
    • to have your information corrected and/or completed
    • to have your information deleted
    • to restrict the use of your information
    • to receive your information in a portable format
    • to object to the use of your information
    • to withdraw your consent to the use of your information
    • to complain to a supervisory authority

 

  • Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.

 

Our details

The data controller in respect of our website is Corinne Hamak Ltd (company registration number: 06717964) the registered office of which is at 110 Regent Road, Leicester, LE1 7LT. You can contact the data controller by writing to Corinne Hamal Ltd, Studio LG04 The Record Hall, 16-16A Baldwins Gardens, London, EC1N 7RJ

or sending an email to info@corinnehamak.com booking@eventmobility.org.uk

 

If you have any questions about this Privacy Policy, please contact the data controller.

 

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Web server log information

We use a third party server to host our website. Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Our server is located in the United Kingdom with Amazon Web Services (aws.amazon.com) / Linode / Digital Ocean.

Use of website server log information for IT security purposes

We and our third party hosting provider store server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our website server provider to make any attempt to identify you from the information collected via server logs.

 

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.
 

Cookies and similar technologies

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies, including essential, functional and analytical cookies. For further information on how we use cookies, please see our cookies policy:

https://www.corinnehamak.com/cookies

You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

 

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

 

Transfer and storage of your information

We use a third party email provider to store emails you send us. Our third party email provider is based in the United States of America.

Emails you send us will be stored outside the European Economic Area on our third party email provider’s servers in the United States of America. For further information and safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

 

Contact form

When you contact us using our contact form, we collect the following information: your name, email address and any information you include in the message field. We also collect your company name if you provide it.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

 

Transfer and storage of your information

Messages you send us via our contact form will be stored on our web servers in the UK and also transferred to our email provider’s servers outside the European Economic Area.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

We use a third party contact form provider to store messages you send us. Our contact form provider is located in the United States of America. Messages you send to us via our contact form will be stored outside the European Economic Area on our contact form provider’s servers in United States of America.

 

Phone

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us. We do not record phone calls.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

 

 

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is sometimes processed by our third party telephone service provider and stored in the United Kingdom.

Post

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

 

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

E-Newsletter

When you sign up for our e-newsletter on our website or opt to receive news and offers we collect your name and email address.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.

 

Transfer and storage of your information

We use a third party service to send out our e-newsletter and administer our mailing list, called Campaign Monitor. You can access their privacy policy below.
https://www.campaignmonitor.com/policies/#privacy-policy
 

 

Information you submit to subscribe for our newsletter will be stored outside the European Economic Area on Campaign Monitor servers in Australia. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

Use of web beacons and similar technologies in emails

We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as the delivery rates, open rates and click through rates which our emails achieve.

For more information on how we use web beacons in our e-newsletter emails, see our cookies policy which is available here: https://www.corinnehamak.com/cookies

For more information about our third party mailing list provider and they use web beacons, please see their privacy policy which is available here:

https://www.campaignmonitor.com/policies/#privacy-policy

 

Registering on our website

When you register and create an account on our website (at checkout), we collect the following information: your name, company name (if applicable), your address (including country, street address, town/city and postcode), phone number, email address and password (we do not view your password).

If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: registering and administering accounts on our website to provide you access to content and updates you have purchased and facilitate the efficient running and operation of our business.

Transfer and storage of your information

Information you submit to us via the registration form on our website will be stored within the European Economic Area on our third party hosting provider’s servers in the United Kingdom.

 


 

Information we collect when you place an order on our website

We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

Information collected when you place an order

Mandatory information

When you place an order for goods or services on our website, we collect the following mandatory information: name, email address, phone number, billing address, company name (if applicable), VAT number (if applicable) and account password (if you create an account).

If you do not provide this information, we will not be able to purchase goods or services from us on our website or enter into a contract with us.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: other than phone number and password, we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: other than phone number and password, we have a legal obligation to issue you with an invoice for the goods and services you purchased from us where you are VAT registered and we require the mandatory information collected by our checkout form for this purpose.

Legal basis for processing: we collect your phone number and password in our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s):

- we collect your password for our legitimate interests in: (i) registering and administering accounts on our website to provide you access to content and updates you have purchased; and (ii) to facilitate the efficient running and operation of our business.

- We collect your phone number for our legitimate interest of more easily and effectively contacting you in relation to your order and your account.

Optional information

We also collect optional information from you, such as your mobile phone number and information about how you heard about us.

Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Legitimate interests: you consent to us processing any optional information you provide by submitting that information to us.

 

Processing your payment

After you place an order on our website you will need to make payment for the goods or services you have ordered. In order to process your payment we use a number of third party payment processors, including PayPal and Stripe / SagePay. Your payment will be processed by the payment provider you choose to process your payment via a payment gateway.

Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.

Third party payment processors

The third party payment processors we use all collect, use and process your information, including payment information, in accordance with their privacy policies. You can access their privacy policies via the following links:

PayPal:https://www.paypal.com/uk/webapps/mpp/ua/privacy-full
Stripe:https://stripe.com/gb/privacy
SagePay: https://www.sagepay.co.uk/policies/privacy-policy

We use OpenCart as the ecommerce platform for processing orders on our website. When you place orders on our website, your information will be processed by OpenCart. OpenCart does not collect any Transfer and storage of your information

 

Transfer and storage of your information

Stripe is based in the United States of America. Information relating to Stripe’s processing of your payment may be transferred outside the European Economic Area to the United States of America. Stripe has self-certified itself with the EU-U.S. Privacy Shield for the purpose of such transfers.

PayPal may transfer information relating to your transaction and the processing of your transaction outside the European Economic Area. Where they do so, they will put appropriate safeguards in place.

SagePay may transfer information relating to your transaction and the processing of your transaction outside the European Economic Area. Where they do so, they will put appropriate safeguards in place.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

 

Information collected or obtained from third parties

This section sets out how we obtain or collect information about you from third parties.

Information received from third parties

Generally, we do not receive information about you from third parties. The third parties from which we receive information about you will generally include other businesses and clients we work with from time to time who may recommend our services to you. These could be business in any industry, sector, sub-sector or location.

It is also possible that third parties with whom we have had no prior contact may provide us with information about you.

Information we obtain from third parties will generally be your name and contact details, but will include any additional information about you which they provide to us.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: where you have asked that a third party to share information about you with us and the purpose of sharing that information is not related to the performance of a contract or services by us to you, we will process your information on the basis of your consent, which you give by asking the third party in question to pass on your information to us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: where a third party has shared information about you with us and you have not consented to the sharing of that information, we will have a legitimate interest in processing that information in certain circumstances.

For example, we would have a legitimate interest in processing your information to perform our obligations under a sub-contract with the third party, where the third party has the main contract with you. Our legitimate interest is the performance of our obligations under our sub-contract.

Similarly, third parties may pass on information about you to us if you have infringed or potentially infringed any of our legal rights. In this case, we will have a legitimate interest in processing that information to investigate and pursue any such potential infringement.

 

Where we receive information about you in error

If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.

 

Information obtained by us from third parties

In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service) we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one). We may do this, for example, if we have insufficient information to be able to contact you or to better understand your business.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.

For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email but we do not possess the information or we need to confirm that we have recorded your email address correctly.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: in certain circumstances, we will have a legitimate interest in obtaining information about you from public and private sources. For example, if you have infringed or we suspect that you have infringed any of our legal rights, we will have a legitimate interest in obtaining and processing information about you from such sources in order to investigate and pursue any suspected or potential infringement.

Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: we may obtain information from third parties, such as data brokers, where you have consented to them sharing information with us by ticking a box stating that you would like your information to be share with us.

 

Our use of automated decision-making and profiling

We use automated decision making and profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.

You have the right to object to our use of automated decision making and profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.

You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here:

https://www.corinnehamak.com/cookies

Automated decision making

Automated decision making is decision making by technological means (i.e. by a machine) without human involvement.

Use of automated decision making for display advertising

We automate the display advertisements containing our products and services on other websites you visit, you based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookies policy which is available here: https://www.corinnehamak.com/cookies

Logic involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.

Significance and envisaged consequences: cookies will be used to recognise the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behaviour.

How to object: you can block these cookies. For further information, please see our cookies policy: https://www.corinnehamak.com/cookies

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest: in certain circumstances, we will show different content on your website. For example, if you are a first time visitor. This will enable us to offer a better experience and avoid showing the same content for each visit.

 

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

 

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

  • Telephone providers (UK)
  • Email provider (USA)
  • Mailing list provider (USA)
  • IT service provider
  • Web developer(UK)
  • Hosting provider (UK)

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not display the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

 

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Providing information to Google Inc.

Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/

 

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

 

Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, affiliates, business partners, independent contractors, and insurers.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: running and managing our business efficiently.

 

Accountants

We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.

Our accountants are located in England.

 

Advisors

Occasionally, we obtain advice from advisors, such as accountants, financial advisors, lawyers and other specialists. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.

 

Our advisors are located in the United Kingdom.

Affiliates

Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their websites, for example. Our affiliates can be in in any industry, sector or sub-sector. Affiliates will share information with us and we will share information with them where you have expressed an interest in our products or services.

Our affiliates are located in the United Kingdom, USA, Australia and New Zealand.

Business partners

Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.

Our business partners are located in the United Kingdom.

Independent contractors

Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them perform in relation to our business.

Our independent contractors are located in the United Kingdom.

Insurers

We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them.

Our insurers are located in the United Kingdom.

 

Disclosure and use of your information for legal reasons

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has been occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that we fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

 

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

 

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): resolving disputes and potential disputes.

 

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one or to the National Crime Agency in connection with suspected or potential money laundering matters.

Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation(s): legal obligations to disclose information which are part of the laws of England and Wales or if they have been integrated into the United Kingdom’s legal framework (for example in the form of an international agreement which the United Kingdom has signed).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations.

 

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

Retention periods

Server log information: we retain information on our server logs for 12 months for security reasons.

Order information: when you place an order for goods and services, we retain that information for a minimum period of six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes under paragraph 6, Schedule 11 of the Value Added Tax Act 1994.

Correspondence and enquiries: when you make an enquiry or contact us by email or via our contact form, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 6 further month(s), after which point we will delete your information.

Mailing list: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier.

 

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • how valuable your information is (both now and in the future);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • how hard it is to ensure that the information can be kept up to date and accurate; and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).

 

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website
  • only transferring your information via closed system or encrypted data transfers; and

 

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

 

Transfers of your information outside the European Economic Area

Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below.

We will also transfer your information outside the EEA or to an international organisation in the unlikely event that we are required to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

 

Email

Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers.

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: our third party email provider has self-certified its compliance with the EU-U.S. Privacy Shield which is available here. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here:

https://ec.europa.eu/info/law/law-topic/data-protection_en

 

E-Newsletter

Information you submit to us when you sign up for our newsletter (your email address) is transferred outside the EEA and stored on our third party mailing list provider’s servers. Our third party mailing list provider is Campaign Monitor. You can access their privacy policy here:
https://www.campaignmonitor.com/policies/#privacy-policy
 

Country of storage:  Australia. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: MailChimp has self-certified its compliance with the EU-U.S. Privacy Shield which is available here:

https://www.privacyshield.gov/welcome

The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here:

https://ec.europa.eu/info/law/law-topic/data-protection_en

 

Google Analytics Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

 

Payment Processing

When you pay for goods and services on your site, if you select Stripe or PayPal, information about your order and the processing of your order may be transferred outside the European Economic Area.

Stripe

Information processed by Stripe is transferred outside the EEA and stored on Stripe’s servers. You can access Stripe’s privacy policy here:

https://stripe.com/gb/privacy

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Stripe has self-certified its compliance with the EU-U.S. Privacy Shield which is available here. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here:

https://ec.europa.eu/info/law/law-topic/data-protection_en

PayPal

PayPal may transfer information they process about your order outside the EEA. Where they do so, they will ensure appropriate safeguards are in place.

You can access PayPal’s privacy policy here:

https://www.paypal.com/ee/webapps/mpp/ua/privacy-full

 

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to Corinne Hamak Ltd, Studio LG04 The Record Hall, 16-16A Baldwins Gardens, London, EC1N 7RJ or sending an email to info@corinnehamak.com

to request access to your information and information related to our use and processing of your information;

  • to request the correction or deletion of your information;
  • to request that we restrict our use of your information;
  • to receive information which you have provided to us in a structured, commonly us

© Copyright 2018 Corinne Hamak

Web design by Cotswold Web Services