PRIVACY POLICY
1. Introduction
1.1 We respect your privacy and are committed to protecting your personal data. This policy applies to your use of the following (and to any related communications with us):
(a) the Courtney Black mobile application software (together with our end-user licence agreement as set out at (EULA) and our app terms and conditions set out at www.courtneyblack.co.uk/terms-conditions once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device) and any of the services accessible through the App (Services).
(b) the Courtney Black website (together with the terms and conditions set out at https://www.courtneyblack.co.uk/terms-conditions) including any data you may provide through the Website when you sign up to our newsletter, purchase a product or take part in a competition/prize promotion.
1.2 Neither the App nor the Website are intended for children and we do not knowingly collect data relating to children.
2. Important information and who we are:
2.1 Courtney Black is made up of different two different legal entities:
(a) Courtney Black App Ltd; and
(b) Courtney Black PT Ltd.
2.2 When we mention "Courtney Black", we are referring to the relevant Courtney Black company responsible for processing your data which will be clear to you when you use our services.
2.3 Courtney Black App Ltd is the controller responsible for the App and Courtney Black PT Ltd is the controller responsible for the Website.
2.4 We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.
2.5 Our full details are:
(a) Full name of legal entity: Courtney Black App Ltd
(b) Name or title of data privacy manager: Chris Curd
(c) Email address: support@courtneyblack.co.uk
2.6 You have the right to make a complaint at any time to the Information Commissioner's Office (ICO).
3. Changes to the privacy policy and your duty to inform us of changes
3.1 We keep our privacy policy under regular review.
3.2 This version was last updated on 7th February 2022. It may change and if it does, these changes will be posted on this page and, where appropriate and relevant to your use of the App, notified to you when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Website, the App or the Services.
3.3 Please keep us informed if your personal data changes during our relationship with you.
4. Third party links
Our Sites (as defined below) may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
5. The data we collect about you
5.1 We may collect, use, store and transfer different kinds of personal data about you as follows:
(a) Identity Data: including first name, last name, username or similar identifier, date of birth, gender.
(b) Contact Data: including billing address, delivery address, email address and telephone numbers.
(c) Financial Data: including bank account and payment card details.
(d) Transaction Data: including details about payments from you and other details of products and services you have purchased from us.
(e) Device Data: including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system and the type of mobile browser you use.
(f) Technical Data: including your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website and the App (as applicable).
(g) Content Data: including information stored on your Device, sign-up information, login information, custom food items you have added, photos, check-ins.
(h) Profile Data: including your username and password, in-App purchase history, purchases or orders made by you on the Website, your interests, preferences, feedback and survey responses. App passwords collected and stored by us are encrypted.
(i) Health Data: including your weight, allergies, health goals and physical activity levels.
(j) Usage Data: including details of your use of the App or your visits to our Website including, but not limited to, traffic data whether this is required for our own billing purposes or otherwise.
(k) Marketing and Communications Data: including your preferences in receiving marketing from us and our third parties and your communication preferences.
5.2 We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App or Website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
5.3 Other than Health Data, we do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Other than Health Data, please do not provide us with any copies of special categories of personal data.
6. How is your personal data collected?
6.1 We will collect and process the following data about you:
(a) Information you give us. This is information you consent to giving us by registering to use the App and the information you give us when you purchase our products or services via our Website or our App (together Our Sites), or by corresponding with us (for example, by email or chat). It also includes information you provide when you make an in-App purchase, share data via the App's functions, enter a competition, promotion or survey, and report a problem with the App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
(b) Information we collect about you and your device. Each time you visit one of Our Sites we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
(c) Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:
(i) Device Data from the following parties:
(A) analytics providers such as Google based outside the UK;
(B) advertising networks based inside or outside the UK; and
(C) search information providers based inside or outside the UK.
(ii) Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based outside the UK.
7. Cookies
We use cookies to distinguish you from other users of the App, the distribution platform (Appstore) or the Website and to remember your preferences. This helps us to provide you with a good experience when you use or browse any of Our Sites and also allows us to improve Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.
8. How we use your personal data
8.1 We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
(a) Where you have consented before the processing.
(b) Where we need to perform a contract we are about to enter or have entered with you.
(c) 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.
(d) Where we need to comply with a legal or regulatory obligation.
8.2 Please see “Lawful Basis” at paragraph 17 below to find out more about the types of lawful basis that we will rely on to process your personal data. You have the right to withdraw that consent at any time by contacting us. Where we rely on consent as our lawful basis you have the right to withdraw your consent at any time by contacting us.
9. Purposes for which we will use your personal data when using the App (and in related communications with us)
1. Introduction
1.1 We respect your privacy and are committed to protecting your personal data. This policy applies to your use of the following (and to any related communications with us):
(a) the Courtney Black mobile application software (together with our end-user licence agreement as set out at (EULA) and our app terms and conditions set out at www.courtneyblack.co.uk/terms-conditions once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device) and any of the services accessible through the App (Services).
(b) the Courtney Black website (together with the terms and conditions set out at https://www.courtneyblack.co.uk/terms-conditions) including any data you may provide through the Website when you sign up to our newsletter, purchase a product or take part in a competition/prize promotion.
1.2 Neither the App nor the Website are intended for children and we do not knowingly collect data relating to children.
2. Important information and who we are:
2.1 Courtney Black is made up of different two different legal entities:
(a) Courtney Black App Ltd; and
(b) Courtney Black PT Ltd.
2.2 When we mention "Courtney Black", we are referring to the relevant Courtney Black company responsible for processing your data which will be clear to you when you use our services.
2.3 Courtney Black App Ltd is the controller responsible for the App and Courtney Black PT Ltd is the controller responsible for the Website.
2.4 We have appointed a data privacy manager. If you have any questions about this privacy policy, please contact them using the details set out below.
2.5 Our full details are:
(a) Full name of legal entity: Courtney Black App Ltd
(b) Name or title of data privacy manager: Chris Curd
(c) Email address: support@courtneyblack.co.uk
2.6 You have the right to make a complaint at any time to the Information Commissioner's Office (ICO).
3. Changes to the privacy policy and your duty to inform us of changes
3.1 We keep our privacy policy under regular review.
3.2 This version was last updated on 7th February 2022. It may change and if it does, these changes will be posted on this page and, where appropriate and relevant to your use of the App, notified to you when you next start the App. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Website, the App or the Services.
3.3 Please keep us informed if your personal data changes during our relationship with you.
4. Third party links
Our Sites (as defined below) may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
5. The data we collect about you
5.1 We may collect, use, store and transfer different kinds of personal data about you as follows:
(a) Identity Data: including first name, last name, username or similar identifier, date of birth, gender.
(b) Contact Data: including billing address, delivery address, email address and telephone numbers.
(c) Financial Data: including bank account and payment card details.
(d) Transaction Data: including details about payments from you and other details of products and services you have purchased from us.
(e) Device Data: including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system and the type of mobile browser you use.
(f) Technical Data: including your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website and the App (as applicable).
(g) Content Data: including information stored on your Device, sign-up information, login information, custom food items you have added, photos, check-ins.
(h) Profile Data: including your username and password, in-App purchase history, purchases or orders made by you on the Website, your interests, preferences, feedback and survey responses. App passwords collected and stored by us are encrypted.
(i) Health Data: including your weight, allergies, health goals and physical activity levels.
(j) Usage Data: including details of your use of the App or your visits to our Website including, but not limited to, traffic data whether this is required for our own billing purposes or otherwise.
(k) Marketing and Communications Data: including your preferences in receiving marketing from us and our third parties and your communication preferences.
5.2 We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App or Website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
5.3 Other than Health Data, we do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Other than Health Data, please do not provide us with any copies of special categories of personal data.
6. How is your personal data collected?
6.1 We will collect and process the following data about you:
(a) Information you give us. This is information you consent to giving us by registering to use the App and the information you give us when you purchase our products or services via our Website or our App (together Our Sites), or by corresponding with us (for example, by email or chat). It also includes information you provide when you make an in-App purchase, share data via the App's functions, enter a competition, promotion or survey, and report a problem with the App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
(b) Information we collect about you and your device. Each time you visit one of Our Sites we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
(c) Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties as set out below:
(i) Device Data from the following parties:
(A) analytics providers such as Google based outside the UK;
(B) advertising networks based inside or outside the UK; and
(C) search information providers based inside or outside the UK.
(ii) Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based outside the UK.
7. Cookies
We use cookies to distinguish you from other users of the App, the distribution platform (Appstore) or the Website and to remember your preferences. This helps us to provide you with a good experience when you use or browse any of Our Sites and also allows us to improve Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.
8. How we use your personal data
8.1 We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
(a) Where you have consented before the processing.
(b) Where we need to perform a contract we are about to enter or have entered with you.
(c) 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.
(d) Where we need to comply with a legal or regulatory obligation.
8.2 Please see “Lawful Basis” at paragraph 17 below to find out more about the types of lawful basis that we will rely on to process your personal data. You have the right to withdraw that consent at any time by contacting us. Where we rely on consent as our lawful basis you have the right to withdraw your consent at any time by contacting us.
9. Purposes for which we will use your personal data when using the App (and in related communications with us)
|
Purpose/activity Data
|
Type of data
|
Lawful basis for processing Data
|
|---|---|---|
| To deliver content to you, To make recommendations to you about goods or services which may interest you, To measure and analyse the effectiveness of the advertising we serve you, To monitor trends so we can improve the App |
Identity, Contact, Device, Content, Profile, Usage, Marketing and Communications, Location
|
Your consent; and Necessary for our legitimate interests (to raise awareness about our products/Services and to develop them and grow our business)
|
|
To administer and protect our business and the App including troubleshooting, data analysis and system testing
|
Identity, Contact, Device
|
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
|
|
To enable you to participate in a prize draw, competition or complete a survey
|
Identity, Contact, Device, Profile, Marketing and Communications
|
Your consent ; and Performance of a contract with you; and Necessary for our legitimate interests (to raise awareness about our products/Services and to develop them and grow our business)
|
|
To manage our relationship with you including notifying you of changes to the App or any Services
|
Identity, Contact, Profile, Marketing and Communications
|
Your consent; and Performance of a contract with you; and Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services); and Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
|
|
To process in-App purchases and deliver Services including managing payments and collecting money owed to us or to refund money back to
|
Identity, Health, Contact, Financial, Transaction, Device, Marketing and Communications, Location,
|
Your consent; and Performance of a contract with you; and Necessary for our legitimate interests (to recover debts due to us)
|
|
To install the App and register you as a new App user
|
Identity, Contact, Device
|
Your consent
|
10. Purposes for which we will use your personal data when using the Website (and in related communications with us)
10. Purposes for which we will use your personal data when using the Website (and in related communications with us)
|
Purpose/Activity
|
Lawful basis for processing
|
Type of data
|
|---|---|---|
|
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences
|
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|
Technical, Usage
|
|
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
|
Necessary for our legitimate interests (to raise awareness about our products/Services and to develop them, to grow our business and to inform our marketing strategy
|
Identity, Contact, Profile, Usage, Marketing and Communications, Technical
|
|
To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting
|
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
|
Identity, Contact, Technical
|
|
To enable you to partake in a prize draw, competition or complete a survey
|
Your consent; and Performance of a contract with you Necessary for our legitimate interests (to raise awareness about our products/Services and to develop them and grow our business)
|
Identity, Contact, Profile, Usage, Marketing and Communications
|
|
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy, (b) Asking you to leave a review or take a survey, (c) Sending you updates and marketing communications
|
Your consent; and Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|
Identity, Contact, Profile, Marketing and Communications
|
|
To process and deliver your order including: (a) Manage payments, fees and charges, (b) Collect and recover money owed to us
|
Your consent; and Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us)
|
Identity, Contact, Financial, Transaction, Marketing and Communications
|
|
To register you as a new customer
|
Your consent; and Performance of a contract with you
|
Identity, Contact
|
11. Disclosures of your personal data
11.1 We may share your personal data for the purposes set out in the tables above with the parties set out below.
(a) Internal Third Parties and External Third Parties as set out in the Glossary.
(b) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
11.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
12. Marketing
12.1 We strive to provide you with choices regarding our use of your personal data, particularly around marketing and advertising.
12.2 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
12.3 You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
12.4 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
13. International transfers
13.1 Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
13.2 If we transfer your personal data out of the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
(a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
(b) Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.
13.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
14. Data security
14.1 All the information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. You are responsible for keeping this password confidential.
14.2 Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
14.3 You may communicate with us publicly through social networking platforms or forum features. You must ensure when doing so that you do not submit any personal data that you do not want to be seen, collected or used by other users.
14.4 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
15. Data retention
15.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
15.2 To determine the appropriate retention period for personal data, we consider: (i) the amount, nature and sensitivity of the personal data; (ii) the potential risk of harm from unauthorised use or disclosure of your personal data; (iii) the purposes for which we process your personal data and whether we can achieve those purposes through other means; and (iv) and the applicable legal, regulatory, tax, accounting or other requirements. For more information on how long we hold your personal data please contact us.
16. Your legal rights
16.1 You have the right to:
(a) Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(i) if you want us to establish the data's accuracy;
(ii) where our use of the data is unlawful but you do not want us to erase it;
(iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) Request the transfer of your personal data to you or to a third party. We will provide to you (or a third party you have chosen) your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
16.2 You also have the right to ask us not to continue to process your personal data for marketing purposes.
16.3 You can exercise any of these rights at any time by contacting us at support@courtneyblack.co.uk.
Glossary
17. Lawful basis
17.1 Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
17.2 Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
17.3 Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
17.4 Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
18. Third parties
18.1 Internal third parties
(a) Other Courtney Black companies acting as joint controllers or processors and who are based in the UK and provide services to you as detailed in this privacy policy.
18.2 External third parties
(a) Service providers acting as processors based in the UK who provide IT and system administration services, website and app development services, including Wix.com (UK) Ltd. and Chris Curd design Ltd.
(b) Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
(c) HM Revenue and Customs, regulators and other authorities acting as processors based in the UK who require reporting of processing activities in certain circumstances.
11. Disclosures of your personal data
11.1 We may share your personal data for the purposes set out in the tables above with the parties set out below.
(a) Internal Third Parties and External Third Parties as set out in the Glossary.
(b) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
11.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
12. Marketing
12.1 We strive to provide you with choices regarding our use of your personal data, particularly around marketing and advertising.
12.2 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
12.3 You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
12.4 Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
13. International transfers
13.1 Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
13.2 If we transfer your personal data out of the UK, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
(a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
(b) Where we use certain service providers, we may use specific contracts approved by the UK which give personal data the same protection it has in the UK.
13.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
14. Data security
14.1 All the information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. You are responsible for keeping this password confidential.
14.2 Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
14.3 You may communicate with us publicly through social networking platforms or forum features. You must ensure when doing so that you do not submit any personal data that you do not want to be seen, collected or used by other users.
14.4 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
15. Data retention
15.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
15.2 To determine the appropriate retention period for personal data, we consider: (i) the amount, nature and sensitivity of the personal data; (ii) the potential risk of harm from unauthorised use or disclosure of your personal data; (iii) the purposes for which we process your personal data and whether we can achieve those purposes through other means; and (iv) and the applicable legal, regulatory, tax, accounting or other requirements. For more information on how long we hold your personal data please contact us.
16. Your legal rights
16.1 You have the right to:
(a) Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(i) if you want us to establish the data's accuracy;
(ii) where our use of the data is unlawful but you do not want us to erase it;
(iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) Request the transfer of your personal data to you or to a third party. We will provide to you (or a third party you have chosen) your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
(g) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
16.2 You also have the right to ask us not to continue to process your personal data for marketing purposes.
16.3 You can exercise any of these rights at any time by contacting us at support@courtneyblack.co.uk.
Glossary
17. Lawful basis
17.1 Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
17.2 Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
17.3 Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
17.4 Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
18. Third parties
18.1 Internal third parties
(a) Other Courtney Black companies acting as joint controllers or processors and who are based in the UK and provide services to you as detailed in this privacy policy.
18.2 External third parties
(a) Service providers acting as processors based in the UK who provide IT and system administration services, website and app development services, including Wix.com (UK) Ltd. and Chris Curd design Ltd.
(b) Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
(c) HM Revenue and Customs, regulators and other authorities acting as processors based in the UK who require reporting of processing activities in certain circumstances.
