Privacy Policy

Welcome to Karen Telfer’s Privacy Policy. It was last updated on 15 May 2018.

Karen Telfer (“we” or “us” or “our”) respects your privacy and is committed to protecting your personal data. The purpose of this privacy notice is to inform you about how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the data protection law protects you.

What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you submit an enquiry, purchase a product or service, request a free meditation track or sign up to our newsletter.

This website is not intended for children and we do not knowingly collect data relating to children. If you become aware that any child has provided us with personal information, please email us immediately at karen@karentelfer.com and we will promptly remove the data.

You must read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

  1. WHO WE ARE AND IMPORTANT INFORMATION
  2. THE PERSONAL DATA WE COLLECT ABOUT YOU
  3. HOW WE COLLECT YOUR PERSONAL DATA
  4. HOW WE USE YOUR PERSONAL DATA
  5. WHO WE SHARE YOUR PERSONAL DATA WITH
  6. INTERNATIONAL TRANSFERS
  7. DATA SECURITY
  8. DATA RETENTION
  9. YOUR LEGAL RIGHTS
  10. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
  11. QUERIES, REQUESTS OR CONCERNS

1. WHO WE ARE AND IMPORTANT INFORMATION
Data controller

Karen Telfer is the controller and responsible for your personal data. We are also the data processor in certain situations. If you have any questions relating to this policy or any requests to update or amend the information or exercise your legal rights, please contact;

Karen Telfer

Brighter Spaces
54 Quarry Street
Guildford
Surrey GU1 3UA

Email: karen@karentelfer.com

Website: www.karentelfer.com

Direct mobile number: 07910 713 582

Third-party links outside of our control

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Dataincludes first name, last name, gender and title.
  • Contact Dataincludes email address, telephone number, location and billing and delivery addresses.
  • Transaction Dataincludes details about payments to and from you and other details of the products or services that you have purchased from us.
  • Technical Dataincludes Internet Protocol (IP address), your 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 this website.
  • Profile Dataincludes purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Dataincludes information about how you use our website, products and services.
  • Marketing and Communications Dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated data such as, statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific 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 notice.

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, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data 

Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services or goods). In this case, we may have to cancel a service or product you have with us but we will notify you of this at the time.

  1. HOW WE COLLECT YOUR PERSONAL DATA 

We use different methods to collect data from and about you via;

  • Direct interactions.You may give us your identity, contact and financial data by filling in forms, purchasing goods or services, corresponding with us by email, phone, face to face, post or otherwise. This includes personal data you provide when you;
  • Apply for our services or a product
  • Request marketing information be sent to you
  • Request extra information via our contact form
  • Subscribe to our newsletters / emails
  • Enter a competition, promotion or a survey
  • Attend a workshop or seminar.
  • Automated technologies or interactions.As you interact with our website, we may collect technical information about your equipment or your browsing patters or actions. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
  • Third parties. We may receive personal data about your from various third parties;
    • Technical data from the following providers
      • Analytical providers
      • Advertising networks
      • Search information providers
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
  1. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Performance of Contractthis 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.
  • Legitimate Interestthis means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the 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). We assess our legitimate interests against any potential impact on you in respect of specific activities.
  • Comply with a legal or regulatory obligationthis means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. You have the right to withdraw consent to marketing at any time by contacting us on karen@karentelfer.com.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, a description of all the ways in which we plan to use your personal data together with the legal bases we rely upon to do so.

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 contact us on karen@karentelfer.com if you need details about the specific legal ground we are relying on to process your personal data.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer/client (a) Identity

(b) Contact

Performance of a contract with you
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

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) 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)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage

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)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)
To target display advertising to users that have previously visited our website and shown interesting in our products and services. (a) Technical

(b) Usage

(c) Profile

Necessary for our legitimate interests (to define customer types and serve relevant messaging to users that are interesting in our products & services).

No Identity or contact data is used in this process. Users can opt out of processing in this way by blocking cookies.

To measure interactions with, and how you share our content on social networks. (a) Technical

(b) Usage

(c) Profile

Necessary for our legitimate interests (to allow users to click through to, follow and like, or share our content on social media).

Data is collected by social media platforms when users use their share, like and follow buttons. For access to this information, or to opt out, users can adjust their account settings on the relevant platforms.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We have established the following personal data control mechanisms:

Promotional offers from us

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.

You will receive marketing communications from us if you have requested information from us, signed up to our newsletter or purchased goods or services from us unless you have opted out of receiving that marketing.

Third-party marketing

We will obtain your express opt-in consent before we share your personal data with any company outside the Karen Telfer group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing messages sent to you or email us at karen@karentelfer.com.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service we provide/provided, contract agreement, product purchased or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please us at karen@karentelfer.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. WHO WE SHARE YOUR PERSONAL DATA WITH 

We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.

  • Internal Third Parties such as team members to fulfil a contract or employees
  • External Third Parties Services such as;
  • Providers who act as processors based in the United States of America who provide CRM systems (Customer Relationship Management), landing pages, websites and IT hosting.
  • Professional advisers who are acting as processors or joint controllers, including lawyers, bankers, auditors and insurers based in the European Economic Area (EEA) who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

  1. INTERNATIONAL TRANSFERS

Many of our external third parties are based outside the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside of the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing safeguards. We ensuring  that the companies have either a privacy shield set up or a GDPR policy in place. Here is a list of the companies that we use outside of the EEA and their terms:

Please contact us www.karentelfer.com/contact if you want further information on the specific locations and terms of use of the companies we use, when transferring your personal data out of the EEA.

  1. 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 employees, agents, contractors and other third parties who have a business need to know. They 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.

  1. 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 requirements.

By law we have to keep basic information about our customers/clients, including invoices, contact, identity, financial and transaction data for six (6) years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights 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.

  1. YOUR LEGAL RIGHTS 

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

  • The right to request a copy of the personal data which we hold about you;
  • The right to request that we correct any personal data if it is found to be inaccurate or out of date;
  • The right to request your personal data is erased where it is no longer necessary to retain such data;
  • The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
  • The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller;
  • The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
  • The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).

If you wish to exercise any of the rights set out above, please email karen@karentelfer.com for subject access rights.

No fee required – with some exceptions 

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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you 

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.

Time limit to respond 

We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer 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.

  1. CHANGES TO THIS NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

  1. QUERIES, REQUESTS OR CONCERNS

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact our data protection controller on karen@karentelfer.com.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Officeon 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.

The content of this document has been written with best practices in mind.