The policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore, the way this website processes, stores and protects user data and information will also be detailed within this policy.
This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience. This website complies to all UK national laws and requirements for user privacy.
1.0 My Core Beliefs Regarding User Privacy and Data Protection
- User privacy and data protection are human rights
- I have a duty of care to the people within my data
- Data is a liability, it should only be collected and processed when absolutely necessary
- I hate spam as much as you do!
- I will never sell, rent or otherwise distribute or make public your personal information
2.0 Relevant Legislation
Along with my business, this website is designed to comply with the following national and international legislation with regards to data protection and user privacy:
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well. If you are unsure about whether this site is compliant with your own country of residences’ specific data protection and user privacy legislation you should contact the DPO (data protection officer) details of whom can be found in section 9.0 for clarification.
3.0 Personal Information That This Website Collects and Why I Collect It
This website collects and uses personal information for the following reasons:
3.1 Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. I use this data to determine the number of people using my site, to better understand how they find and use my web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google does not grant us access to this. I consider Google to be a third party data processor (see section 6.0 below).
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages on this website.
3.2 Contact via forms
Should you choose to contact me using the contact forms on my site (including on my Contact us page), the data you supply will be stored by this website but it will only be used for the purpose it was submitted for, i.e. to respond to your enquiry. Data submitted via forms is kept for a period of 24 months.
Some of the forms on my website are linked to my CRM system (HubSpot – read about GDPR compliance here).
From time-to-time, I do not hear back from people to whom I send quotations, proposals or other information. Should this happen, I will send you follow-up emails to ascertain whether you would like to continue communication with me regarding your enquiry.
I will email you about your specific enquiry until you confirm that you no longer wish to receive further communication.
Should you confirm prior to the fourth email that you no longer wish to receive further information from me in regard to your enquiry, I will delete your data from my CRM upon receipt of such request.
3.3 Contact via email
If you contact me via one of my @cebcreative.co.uk or email addresses, your email will be securely stored on my email servers which are provided by Google (read their GDPR policy here).
I will only use your email address to contact you in regard to your enquiry.
Your email address will not be shared with anyone outside of my company.
All email communications are stored in my Google email account for up to seven years or until such time as I delete them (whichever event happens first).
3.4 Email newsletter
If you choose to join my email newsletter, the email address that you submit to me will be forwarded to MailChimp who provide me with email marketing services. I consider MailChimp to be a third party data processor (see section 6.0 below). The email address that you submit will also be stored within this website’s own database as explained in section 3.2.
Your email address will remain within MailChimp’s database for as long as I continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that I send you or by requesting removal via emailing the DPO contact details. When requesting removal via email, please send your email using the email account that is subscribed to the mailing list so I can verify your identity and right to edit the data I hold.
If you are under 18 years of age you MUST obtain parental consent before joining my email newsletter.
While your email address remains within the MailChimp database, you will receive periodic (approximately four times a year) newsletter-style emails from me.
4.0 How I store your personal information
As detailed in section 3.2 above, if you submit an enquiry through my website some personal information will be stored in this website’s database. This is currently the only occasion where personal data will be stored on this website. This data is currently stored in an identifiable fashion; a limitation of the content management system that this website is built on (WordPress). In the near future, I aim to change the storage of this data to a pseudonymous fashion meaning that the data would require additional processing using a separately stored ‘key’ before it could be used to identify an individual.
Pseudonymisation is a recent requirement of the GDPR which many web application developers are currently working to fully implement. I am committed to keeping it as a high priority and will implement it on this website as soon as I am able to.
5.0 About my website’s server
This website is hosted by WP Engine within a UK data centre located in London. More information on WP Engine’s GDPR compliance can be found here.
WP Engine use AWS (Amazon Web Server and Google as datacenter provider partners. You can read more on Google Cloud’s GDPR compliance here and more on AWS’s GDPR compliance here.
Full details of Goolge Cloud’s security compliance can be found here.
All traffic (transferral of files) between this website and your browser is encrypted and delivered over HTTPS.
6.0 My third party data processors
I use a number of third parties to process personal data on my behalf. These third parties have been carefully chosen and all of them comply with the legislation set out in section 2.0. Three of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.
7.0 Data breaches
I will report any unlawful data breach of this website’s database or the database(s) of any of my third party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
8.0 Data controller
The data controller of this website is: CEB Creative, a Sole Trader.
9.0 Data protection officer
Miss Charlotte Brown, owner, CEB Creative.
10.0 External Links
Although this website only looks to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text/banner/image links to other websites, similar to; thelittlecarnivorecompany.co.uk or The Little Carnivore Co.)
The owner of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should, therefore, note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
11.0 Social Media Platforms
Communication, engagement and actions taken through external social media platforms that this website and its owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate/engage upon them with due care and caution in regard to their own privacy and personal details. This website nor its owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.
This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
12.0 Shortened Links in Social Media
This website and its owner through their social media platform accounts may share web links to relevant web pages. By default, some social media platforms shorten lengthy URLs [web addresses] (this is an example: https://bit.ly/zyVUBo).
Users are advised to take caution and good judgement before clicking any shortened URLs published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine URLs are published many social media platforms are prone to spam and hacking and therefore this website and its owner cannot be held liable for any damages or implications caused by visiting any shortened links.
13.0 Resources & Further Information