Your data / My privacy policy

 

Privacy Policy valid from: 1st May 2022

 

Introduction

Your privacy is really important to me, and GDPR has formalised how much this matters.

If you’re here reading this, maybe you got lost, and you were looking for my (upcoming) podcast, or how to work with me, or, you might be one of the few people who actually read these policies! Good on you – I know there were some huge companies that did whatever they liked with your data, all without telling you. That’s just not right, and I’m glad you’re taking an interest.

 Here's an overview of the data I collect and process through my websites hearttoheartsales.com (hearttoheartsales.co.uk /beckycolwell.co.uk / beckycolwell.com all link to this too).  I’ve tried to reduce the formality of this information as much as possible, but hey, these things have to be written in the right way, don’t they?

The data I collect, and where do I hold it

I am the data controller and I am responsible for your personal data. I keep it safe, and if you ever need to update your information, then please email me at [email protected].

 I 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. I also do not collect any information about criminal convictions and offences.

 I use Kajabi for my website, courses, and transactions, and they are based in California, USA. They are the data processor of your data. They never use your data independently of me. I have reviewed their very comprehensive data processing statements, and I trust them with their focus in keeping your data safe (you can see them here: https://kajabi.com/policies).

I use your data for sending my newsletter, and you can opt out at any time If you want me to delete your data at any time, please email me at [email protected].

 When you’ve processed transactions with me, I may need to hold onto your data for legal purposes. I will never sell any of your information. I will not share any of your information without express prior agreement.  When we work together I keep confidential paper notes which are not shared with anyone. Sometimes your data is saved in a password protected folder on my device. Data is saved is for the purposes of our communications via zoom / telephone / voxer, and as an aide-memoire so that I can give you the best training and coaching experience. As well as technical data around the use of this website, I may collect some of the following data from you during our online or face to face interactions – your name; your contact information; gender; profession and job title; demographic information such as interests, where you live, your preferences; financial information.

 From time to time I might have to share some of your data with governing bodies or professionals such as tax officials, accountants, auditors, lawyers, insurers. I require and expect any of these 3rd parties to be respectful of all data processing laws, and be focussed on the privacy and security of your data, to act within all data laws, and to treat your data in accordance with these laws. Your data will only be shared with these bodies and professionals for very specific purposes and I would require them only process your data for those specified purposes.

 When we email, I will keep your email address safe, I may share it with those bodies and or professionals mentioned above, I won’t share it with anyone else without your permission and I will never sell it. If you choose to correspond with me via email, I may retain the content of your email messages, your email address, and my response. The same protections are used for your email as for all of your information.  If you are registered for marketing from me, all of these emails will have a clear unsubscribe button, so that if you decide you don’t want marketing emails from you, then you won’t.  I may send you marketing communications if (i) you made a purchase or asked for information from me about my goods or services or (ii) you agreed to receive marketing communications or (iii) you are a limited company who I believe could benefit from my services - and in each case you have not opted out of receiving such communications since.

 I may collect information about you, such as your IP address, details about your browser (i.e Safari, Chrome, Firefox), the amount of time you spend on the pages of my website, your page views and navigation paths, details about the number of times you use my website, time zone settings and other technology on the devices you use to access my website. The source of this data is from the analytics tracking system I use called Google Analytics. I process this data to analyse your use of my website to administer and protect my business and website, to deliver relevant website content and advertisements to you, and to understand the effectiveness of any advertising.

I may also receive data from third parties, such as analytics providers like Google based outside the EU, advertising networks such as Facebook based outside the EU, or providers of Payment services such as Paypal, based outside the EU and Stripe.

If I transfer your data outside the EU, I will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data, or Service Providers that have 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 Companies that are part of part of EU-US Privacy Shield, who have equivalent safeguards in place.

What do I do with your data & how long do I keep it for?

I will only keep hold of your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 When I decide how long to keep the data for, I look at what is the purpose, and can I achieve that purpose by another means. I look at the amount of data, it’s sensitivity, the potential risk of harm to you should there be unauthorised use or disclosure, and also the processing purpose.

I am required to keep basic information about my clients (including contact information, financial and transaction data) for six years after they stop being clients, this is for tax and accounting purposes.

I might anonymise your personal data for research or statistical purposes in which case I may use this information indefinitely without further notice to you.

Your legal rights

Under data protection laws in the EU and UK you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent. You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

Wherever you are based in the world, regardless whether you are covered by European or UK directives, (hello my US & Canadian Clients), if you wish to exercise any of the rights set out above, please email me at [email protected], ideally with the title Personal Data Request. I’ll do my best to respond within the month, occasionally it may take me longer than a month if your request is particularly complex or you have made repeated or multiple types of requests. In this case, I will notify you.

You don’t need to pay a fee to access your personal data, although I reserve the right to charge a fee if your request is repetitive, excessive, or unfounded and within law, I can also refuse to comply if this is the case. Remember that I may need to request specific information from you to help me confirm your identity, before I share any personal data with you, additional data might also be needed to speed up your request.

 If you are not happy with any aspect of how I collect and use your data, I’d be grateful if you let me know, so that I can try to resolve it for you. 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).

What about links on my website to third-party sites?

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. I do not control these third-party websites and I am not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy notice of every website you visit. If I were to ever have affiliate links on my site, I’ll let you know on that page.

 Contact me

Heart to Heart Sales™ and Becky Colwell welcome any questions about our Privacy Policy, Life, Cookie Policy, and Services – either email on [email protected] or by post at Heart to Heart Sales, The Old Sweet Shop, 20 Newbury Street, Lambourn, RG17 8PF, UK

Changes to this Privacy Policy

I will update this privacy policy as often as is needed to comply with the law and to reflect my current working practices. Any changes will be made here in a timely manner, and your continued use of my website (after any change) is deemed as your acceptance of those changes. The date on which this Privacy Policy was updated is shown above.

Disclaimers

Accountability for content

I’ve created the contents of my website with the utmost care and this does not constitute a guarantee, I am responsible for all of my content on these pages.

Accountability for links

I have checked all links before linking to the web pages of other companies that I believe are relevant. Responsibility for the content of those links lies solely with the operators of the linked pages. Please let me know if you are concerned with any of these links.

Copyright

My web pages and contents are subject to copyright law. Unless expressly permitted by law or by me, please do not copy or utilise the content without prior written consent. Unauthorised use may result in copyright violations.

 

 Cookie Policy

What are cookies

Hmmm, in my real world they are gorgeous biscuits with chocolate chips in.

In the online world they are used by nearly all websites, and cause no harm to you, your cholesterol, or devices.

A cookie is a little bit of information stored on your device and can be used to analyse traffic to my website. They can also record how you move around a website, so that when you revisit it, it can present tailored options based on your last visit. In addition, they can be used for advertising and marketing purposes.

If you want to check or change what types of cookies you accept, this can usually be altered within your browser settings. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of my site.

By your continued use of this website you are consenting to my use of cookies, and acknowledge that you have the ability to disable any cookies through your own browser with the understanding that doing so may affect your browsing experience and the performance of this site.

Cookies are either:

Session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer; or

Persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again. I use persistent cookies for Google Analytics.

Cookies can also be categorised as follows:

Strictly necessary cookies: These cookies are essential to enable you to use the website effectively, such as when buying a product and / or service, and therefore cannot be turned off. Without these cookies, the services available to you on our website cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.

Performance cookies: These cookies enable me to monitor and improve the performance of my website. For example, they allow me to count visits, identify traffic sources and see which parts of the site are most popular.

Functionality cookies: These cookies allow my website to remember choices you make and provide enhanced features. For instance, I may be able to provide you with news or updates relevant to the services you use. They may also be used to provide services you have requested suh as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised. 

How do I use cookies?

I use cookies to track your use of my website. This enables me to understand how you use the site and track patterns. This helps me to develop and improve my website as well as products and/or services in response to what you might need or want. By continuing to use this website you are consenting to the use of cookies

Kajabi’s cookie notice is https://kajabi.com/policies/cookie-notice and does apply to sites run by them, ie this one.

In addition

Universal Analytics (Google)

The cookies collect information in an anonymous form, including the number of visitors to our websites, where visitors have come to the sites from and the pages they visited. We use the information to help us improve the website and to see whether we have been mentioned in articles or on referring sites that we otherwise might not have been aware of. Click here to read Google’s overview of privacy and safeguarding data

Adwords (Google)

I may occasionally run online advertising campaigns to attract visitors to specific pages, events and content on my website. These cookies allow me to display ads that are relevant to specific users and to track whether my campaign is attracting visitors. Click here to read Google’s overview of privacy and safeguarding data

YouTube

I may embed videos from my official YouTube channel using YouTube’s privacy-enhanced mode. This mode may set cookies on your computer once you click on the YouTube video player, but YouTube will not store personally identifiable cookie information. Read more at YouTube’s embedding videos information page.

Social Website Cookies

So you can easily “Like” or share our content on the likes of Facebook and Twitter, I include sharing buttons on my site which may install cookies. The privacy implications on this will vary from social network to social network and will be dependent on the privacy settings you have chosen on these networks.

Online Payments

When you make a booking or buy an item from my website, I do not see any of your payment information. To allow payments to happen, I use secure, PCI and GDPR compliant, encrypted third-party services and software that may install cookies. I use standard payment integrations with PayPal and Stripe.

PayPal Privacy Policy:  https://www.paypal.com/uk/webapps/mpp/ua/privacy-full   

Stripe Privacy Policy:  https://stripe.com/en-gb/privacy-center/legal

Kajabi Policies:  https://kajabi.com/policies

How can I disable cookies?

You can accept, decline, or set your browser to alert you when cookies are sent to your web browser. There are links below that may help if that’s what you want to do – but be aware that certain functions of my site may not work properly if you turn stuff off:

 Encryption of Data

SSL certificates are used to verify our identity to your browser and to encrypt any data you give us. Whenever data is transferred between us, you can check that it is done using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

 Recipe

Here’s a recipe for cookies, these look fabulous, but I have to admit that it took me so much time to write these policies, I’ve not had time to try them! https://www.bbcgoodfood.com/recipes/chocolate-chunk-cookies

 

Seriously though, if you ever have ANY questions about these please get in touch asap. Despite the recipe joke to lighten the heavy reading, I take this - and your data - very very seriously.