1. DEFINITIONS AND INTERPRETATION
Collectively all information that you submit to Flavia Cortez Ltd via the Website. This definition incorporates, where applicable, the definitions provided in the General Data Protection Regulation (GDPR) and the Data Protection Act 1998;
An account required to access and/or use certain areas and features of the Website:
A small text file placed on your computer or device by the Website when you visit certain parts of the Website and/or when you use certain features of this Website. Details of the Cookies used by this Website are set out in section 11, below;
The website that you are currently using, , and any sub-domains of this site unless expressly excluded by their own terms and conditions;
"UK and EU Cookie Law"
The Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015;
“We/ Us/ Our”
Flavia Cortez Ltd, a company incorporated in England and Wales with registered number XXXXXX whose registered address is 33 Ellerman Avenue, Twickenham, England, TW2 6AA; and
Any third party that accesses theWebsite and is not either (i) employed by Flavia Cortez Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Flavia Cortez Ltd and accessing the Website in connection with the provision of such services.
2. WHAT DOES THIS POLICY COVER?
3. WHAT DATA DO WE COLLECT?
3.1 Full Name;
3.2 Email Address
3.3 Telephone Number
3.4 Company name
3.5 Company Information
3.7 Credit / Debit card details
3.8 IP address
3.9 Web browser type and version
3.10 Operating System
3.11 A list of URLs starting with a referring site, your activity on the Website, and the site you exit to
4. HOW DO I USE YOUR DATA?
4.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 5, below.
4.2 We use your data to provide the best possible products and services to you. This includes:
4.2.1 Providing and managing your Account
4.2.2 Providing and managing your access to the Website
4.2.3 Personalising and tailoring your experience on the Website
4.2.4 Supplying Our products and services to You
4.2.5 Personalising and tailoring Our products and services for You
4.2.6 Responding to communications from You
4.2.7 Supplying you with email newsletters, alerts etc. that you have subscribed to (You may unsubscribe or opt-out at any time by clicking the ‘update your preferences’ link in the email or by contacting Us at email@example.com
4.2.8 Market research
4.2.9 Analysing your use of the Website and gathering feedback to enable Us to continually improve the Website and Your user experience.
4.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide You without your consent for Us to be able to use such Data.
4.4 Once You have submitted Your Data, We use Your data for marketing purposes which may include contacting You by email, telephone, text message with information, news and offers on Our products and services. We will not, however, send You any unsolicited marketing or spam and will take all reasonable steps to ensure that Your rights are fully protected and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
4.5 Advertisers whose content appears on the Website may engage in what is known as “behavioural advertising” – advertising which is tailored to Your preferences, based on Your activity. Your activity is monitored using Cookies, as detailed below in section 11. You can control and limit Your data used in this way by adjusting Your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of Your Data in this way will not remove the advertising, but it will make it less relevant to Your interests and activities on the Website.
4.6 Under GDPR we will ensure that Your personal Data is processed lawfully, fairly, and transparently, without adversely affecting Your rights. We will only process Your personal Data if at least one of the following basis applies:
a) You have given consent to the processing of Your personal Data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which You are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which We are subject;
d) processing is necessary to protect the vital interests of You or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by Us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the Data subject which require protection of personal data, in particular where the data subject is a child.
5. HOW AND WHERE DO WE STORE YOUR DATA?
5.1 I only keep Your Data for as long as needed in order to use it as described above in section 4, and/or for as long as We have Your permission to keep it. In any event, Your Data will be deleted if you notify us via email, telephone or post.
5.2 Some or all of Your Data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using the Website and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that Your Data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage with.
5.3 Data security is of great importance to Us, and to protect Your Data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through the Website.
5.4 We shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal Data:
• All employees, agents, contractors, or other parties working on Our behalf shall be made fully aware of both their individual responsibilities and Our responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy;
• Only employees, agents, sub-contractors, or other parties working on behalf of the Flavia Cortez Ltd that need access to, and use of, personal Data in order to carry out their assigned duties correctly shall have access to personal data held by the Flavia Cortez Ltd;
• All employees, agents, contractors, or other parties working on behalf of the Flavia Cortez Ltd handling personal data will be appropriately trained to do so;
• The performance of those employees, agents, contractors, or other parties working on behalf of the Flavia Cortez Ltd handling personal Data shall be regularly evaluated and reviewed;
• All employees, agents, contractors, or other parties working on behalf of the Flavia Cortez Ltd handling personal Data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract;
• All agents, contractors, or other parties working on behalf of the Flavia Cortez Ltd handling personal Data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Flavia Cortez Ltd arising out of this Policy and the Regulation.
5.5 Notwithstanding the security measures that We take, it is important to remember that the transmission of Data via the internet may not be completely secure and that You are advised to take suitable precautions when transmitting to Us data via the internet.
6. DO WE SHARE YOUR DATA?
6.1 We may only share Your Data with wholly owned subsidiaries of Flavia Cortez Ltd.
6.2 We may contract with third parties to supply products and services to You on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of Your Data. Where any of Your Data is required for such a purpose, We will take all reasonable steps to ensure that Your Data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with:
Below are details of Third-party Name and Type of data subject
Google: First name, last name, email address
ConvertKit: First name, last name, email address
Facebook: First name, last name, email address
Stripe/ PayPal: First name, last name, email address, company information, purchase invoices
Royal Mail and Couriers: First name, last name, Company Name, Address
6.3 We may compile statistics about the use of the Website including Data on traffic, usage patterns, User numbers, sales and other information. All such Data will be anonymised and will not include any personally identifying information. We may from time to time share such Data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
6.4 In certain circumstances We may be legally required to share certain Data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from You in order to share Your Data in such circumstances and will comply as required with any legally binding request that is made of Us.
7. WHAT HAPPENS IF THE BUSINESS CHANGES HANDS?
7.2 In the event that any of Your Data is to be transferred in such a manner, You will be contacted in advance and informed of the changes. When contacted You will be given the choice to have Your Data deleted or withheld from the new owner or controller.
8. HOW CAN YOU CONTROL YOUR DATA?
8.1 When You submit information via the Website, You may be given options to restrict Our use of Your Data. We aim to give You strong controls on Our use of Your Data (including the ability to opt-out of receiving emails from Our which You may do by unsubscribing using the links provided in Our emails or by emailing Us to let Us know Your preferences).
8.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent You receiving unsolicited marketing. Please note, however, that these services will not prevent You from receiving marketing communications that You have consented to receiving.
9. YOUR RIGHT TO WITHHOLD INFORMATION AND YOUR RIGHT TO WITHDRAW INFORMATION AFTER YOU HAVE GIVEN IT
9.1 You may access certain areas of the Website without providing any Data at all. However, to use all features and functions available on the Website You may be required to submit or allow for the collection of certain Data.
9.3 You may withdraw Your consent for Us to use your personal Data as set out in section in 4 at any time by contacting Us using the details set out in section 14, and We will delete Your Data from Our system. However, You acknowledge this may limit Our ability to provide the best possible products and services to You.
10. HOW CAN YOU ACCESS YOUR DATA?
10.1 You have the legal right to ask for a copy of any of Your personal Data held by Us (where such Data is held). Please contact Us for more details using our contact form,or using the contact details below in section 14.
10.2 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 or refuse to comply with Your request in these circumstances.
11. WHAT COOKIES DO I USE AND WHAT FOR?
11.2 By using the Website You may also receive certain third party Cookies on Your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. We use third-party Cookies on the Website for advertising services. For more details, please refer to section 4, above, and to section 11.6 below. These Cookies are not integral to the functioning of the Website.
11.3 All Cookies used by and on the Website are used in accordance with current English and EU Cookie Law.
11.5 Certain features of the Website depend on Cookies to function. UK and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 11.6. Your consent will not be sought to place these Cookies. You may still block these Cookies by changing Your internet browser’s settings as detailed below in section 11.10, but please be aware that the Website may not work as intended if You do so. We have taken great care to ensure that Your privacy is not at risk by allowing them.
11.6 We do not place first-party Cookies on Your computer or device, however, the following third-party Cookies may be placed on Your computer or device:
Name of Cookie :Facebook
11.7 The Website uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use the Website. This, in turn, enables us to improve the Website and the products and services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to Your privacy or your safe use of the Website, it does enable Our to continually improve the Website, making it a better and more useful experience for You.
11.8 The analytics service(s) used by the Website use(s) Cookies to gather the required information. These Cookies may be placed immediately when You first visit the Website and it may not be possible for Us to obtain Your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 11.10.
11.9 The analytics service(s) used by the Website use(s) the following Cookies:
Name of Cookie: Google
First / Third Party: Third
11.10 You can choose to enable or disable Cookies in Your internet browser. Most internet browsers also enable You to choose whether You wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in Your internet browser or the documentation that came with Your device.
11.11 You can choose to delete Cookies at any time however You may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, login and personalisation settings.
11.12 It is recommended that You keep Your internet browser and operating system up-to-date and that You consult the help and guidance provided by the developer of your internet browser and manufacturer of Your computer or device if You are unsure about adjusting Your privacy settings.
12. SUMMARY OF YOUR RIGHTS UNDER GDPR
Under the GDPR, you have:
12.1 the right to request access to, deletion of or correction of, Your personal Data held by Us;
12.2 the right to complain to a supervisory authority;
12.3 be informed of what Data processing is taking place;
12.4 the right to restrict processing;
12.5 the right to Data portability;
12.6 object to processing of Your personal Data;
12.7 rights with respect to automated decision-making and profiling (see section 13 below).
14. CONTACTING US