This privacy notice provides you with details of how we collect and process your personal data.
Mark Hibbert is the data controller and responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our email address is email@example.com.
Our postal address is 15 The Heathers, Boughton, Newark, Nottinghamshire, NG22 9HE, England.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information
Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be
grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time
your personal information changes by emailing us at firstname.lastname@example.org.
We do not collect any Sensitive Data about you. Sensitive Data refers to data that includes details about your race or
ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership,
information about your health and genetic and biometric data. We do not collect any information about criminal
convictions and offences.
2. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are:
Where we need to perform the contract between us.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at email@example.com.
Purposes for processing your personal data
Set out below is a description of the ways we may use your personal data and the legal grounds on which we will process
such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are
using your data. Please email us firstname.lastname@example.org if you need details about the specific legal ground we are relying
on to process your personal data where more than one ground has been set out in the table below.
We process data about you to register you as a new contact, to manage our relationship with you, to complete a survey which will assist our legitimate interests to develop and grow our business, to administer and protect our business and our site, to deliver relevant content to you and measure and understand the effectiveness of our services, and to make suggestions and recommendations to you about news which may be of interest to you. We may process the following categories of personal data about you:
Communication Data that includes any communication that you send to us whether that be through the contact form on
our website, through email, text, social media messaging, social media posting or any other communication that you send
us. We process this data for the purposes of communicating with you, for record keeping and for the establishment,
pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are
to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
User Data that includes data about how you use our website and any online services together with any data that you post
for publication on our website or through other online services. We process this data to operate our website and ensure
relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or
databases and to enable publication and administration of our website, other online services and business. Our lawful
ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website
and our business.
Technical Data that includes data about your use of our website and online services such as your IP address, your login
data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the
number of times you use our website, time zone settings and other technology on the devices you use to access our
website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our
website and other online services, to administer and protect our business and website, to deliver relevant website content
and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is
our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow
our business and to decide our marketing strategy.
Marketing Data that includes data about your preferences in receiving marketing from us and your communication
preferences. You will receive communications from us if you have: requested information from us; and have not opted out
of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third
party for marketing purposes. You can ask us, or third parties, to stop sending you marketing messages at any time by
emailing us at email@example.com any time. Our lawful ground for this processing is our legitimate interests which in
this case are to study how customers use our products/services, to develop them, to grow our business and to decide our
3. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in
accordance with the law. We only allow such third parties to process your personal data for specified purposes and in
accordance with our instructions.
4. INTERNATIONAL TRANSFERS
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal
data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain
Some of our third parties service providers (Dropbox, Mailchimp) are based outside the EEA so their processing of your
personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by
ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
• Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at firstname.lastname@example.org if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.
5. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or
accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those who will
only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable
regulator of a breach where we are legally required to do so.
6. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the
purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the
personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which
we process your personal data and whether we can achieve those purposes through other means, and the applicable legal
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data)
for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include
the right to:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at email@example.com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We have created a document explaining all of this further, which can now be viewed here.