This privacy notice provides you with details of how we collect and process your personal data through your communications with us including your use of our site https://www.giancarloserra.org/ in accordance with the General Data Protection Regulation (GDPR).
The Giancarlo Serra’s website is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our full details are:
Full name of legal entity: Giancarlo Serra
Email address: firstname.lastname@example.org
Telephone number: +44 77 8649 7360
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com.
WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUNDS WE PROCESS IT.
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We will only use your personal data when legally permitted. The most common uses of your personal data are:
– Where we need to perform the contract between us.
– Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
– Where we need to comply with a legal or regulatory obligation.
– We may process the following categories of personal data about you:
Communication Data which could include any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting, application forms or any other communication that you send us.
We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance, or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Customer Data which could include data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, telephone number and any instant message IDs, purchase details and your PayPal, card and bank details.
We process this data to supply the goods and/or services you have purchased, to recover debts owed to us and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract, and also necessary for our legitimate interests to collect and recover money owed to us.
User Data which could include data about how you use our website and services together with any data that you post for publication on our website or through other online services, how frequently you use our services, the products and or services you have expressed an interest in and how you use our website(s) and which pages you have visited, your username, email address, access password, purchase history, your interests and preferences, feedback and responses to surveys, and to notify you about changes to our terms, policies or procedures.
We process this data to manage our relationship with you, to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is performance of a contract with you, necessary to comply with a legal obligation, necessary for our legitimate interests which in this case are to enable us to properly administer, develop and grow our website and our business.
Technical Data which could include data about your use of our website and online services such as your IP address, your login data, date and time of access, details about your web browser type and version number, web browser plug-ins and type, time zone and location, your devices operating system and platform (Windows, Mac OS, Android), length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system and web site access logs.
We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business, for the provision of administration and IT services, network security, and to grow our business and to decide our marketing strategy.
Marketing Data which could include data about your preferences on how we can communicate with you including sending marketing information for us or a third party and product update notifications. We process this data to enable you to partake in our promotions such as competitions and prize draws, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook, Instagram, MailChimp and Eventbrite adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
Application Data which could include data relating to the services for which you are applying such as your name, title, addresses, telephone numbers, email addresses, date of birth, passport details, photograph, gender, marital status and dependants, sexual orientation, health, medication and medical treatment, dietary needs, details of current and previous employment and training, information about current and previous therapies received and provided, professional memberships and insurance, criminal convictions and offences and any other information included in an application form, CV or covering letter/email or as part of the application process.
We process this data to ensure that the service for which you are applying is appropriate and suitable, to meet legal, accreditation, membership, insurance and record-keeping requirements, and to ensure the health, safety and well-being of yourself and others. If you decide not to provide us with certain personal data that we have requested, we may not be able to perform contracts between us or we may be prevented from complying with our legal obligations.
Our lawful ground of processing is performance of a contract between you and us and/or taking steps at your request to enter into such a contract, consent, necessary to comply with a legal obligation and also necessary for our legitimate interests to keep records and to establish, pursue or defend legal claims, to enable us to properly administer and develop our business and services.
Special Category Data
We may need to collect the following sensitive data about you in order to deliver the services:
Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, marital status and dependants, sex life, sexual orientation, political opinions, trade union membership, passport details, date of birth, dietary needs, next of kin and emergency contact details, information about your health, medication and medical treatment, criminal convictions and offences.
We process this data to supply the services for which you apply, the services you purchase, and to ensure the health, safety and well-being of yourself and others. Our lawful ground for this processing is consent, the performance of a contract between you and us and/or taking steps at your request to enter such a contract.
We require your explicit consent for processing sensitive data and we will ask you to confirm your consent to this processing.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at firstname.lastname@example.org. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
HOW WE COLLECT YOUR PERSONAL DATA
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook and MailChimp based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as PayPal based outside the EU and Eventbrite based inside the EU.
We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
We do not pass on your details to third parties for their own marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by emailing us at email@example.com at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, applications for courses, membership etc.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, accountants, auditors and insurers.
Government bodies that require us to report processing activities.
Retreat venues, course tutors and facilitators, membership associations.
Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions, and they must keep it confidential.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
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.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after the end of the accounting period.
For purposes of our Membership & Accreditation Association and insurance we are required to keep the records for at least 7 years following the last occasion on which treatment was given. In the case of treatment to minors, records should be kept or at least 7 years after they reach the age of majority (18).
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under data protection laws 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:
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org.
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.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
Our 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.