Privacy Policy
1. INTRODUCTION
This privacy notice provides you with details of how I collect and process your personal data through your use of the site www.robashton.com
By providing us with your data, you warrant to us that you are over 13 years of age.
Emphasis Training Ltd is the data controller and responsible for your personal data (referred to as ‘we’, ‘us’ or ‘our’ in this privacy notice).
Contact Details
Our full details are as follows.
Full name of legal entity: Emphasis Training Ltd
Email address: rob@robashton.com
Postal address: 1 Amber House, St John’s Road, Hove BN3 2EZ
Telephone number: +44 (0)1273 732 888
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 info@writing-skills.com. You can also adjust your settings using the link at the bottom of every marketing email we send.
2. 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 may process the following categories of personal data about you:
Communication Data that includes 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 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 that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased 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.
User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data 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 our legitimate interests which in this case are to enable us to properly administer our website and our business.
Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. 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 and to grow our business and to decide our marketing strategy.
Marketing Data that includes data about your preferences in receiving marketing from us and your communication preferences. With your consent (where required) we process this data to enable you to partake in our business-writing promotions such as competitions, prize draws and free giveaways, 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 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).
Sensitive Data
We 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. We do not collect any information about criminal convictions and offences.
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 info@writing-skills.com. 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.
3. HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies.
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook, including search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
4. MARKETING COMMUNICATIONS
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. The marketing emails we send you will contain tracking pixels that allow us to see how you interact with the email. This will help us provide you with more relevant content. You can, however, opt out at any time.
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.
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 message sent to you or by emailing us at rob@robashton.com.
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, warranty registrations etc.
5. 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, auditors and insurers
• Government bodies that require us to report processing activities.
We may share this data with advertising platforms we use, such as Facebook, Google Adwords, Linkedin or Twitter, to advertise to you or create lookalike audiences based on your interaction with our website and your interests.
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.
6. INTERNATIONAL TRANSFERS
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.
Some 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.
7. DATA SECURITY
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.
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.
8. 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.
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 they stop being customers.
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.
9. 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:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at info@writing-skills.com
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 we may 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.
10. THIRD-PARTY LINKS
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.
11. 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. For more information about the cookies we use, please see below.
Cookie policy
We use cookies to help us:
• make our website work as you’d expect
• remember your settings during and between visits
• improve the speed/security of the site
• allow you to share pages with social networks like Facebook
• continually improve our website for you
• make our marketing more efficient (which ultimately keeps down the costs to you).
We do not use cookies to:
• collect personally identifiable or sensitive information without your express permission
• pass data to advertising networks
• pass personally identifiable data to third parties
• pay sales commissions.
You can learn more about all the cookies we use below.
Granting us permission to use cookies
If your browser is set to allow cookies, we take this as your implicit consent to receive cookies from our site. Should you wish to remove or not use cookies from our site, you can learn how to do this below. But this may mean that our site will not work as you would expect.
Website function cookies
Our own cookies
We use cookies to make our website work including:
• remembering your search settings
• allowing you to add comments to our site.
Unfortunately there is no way to prevent these cookies being set if you use our site.
Third party functions
Our site, like most websites, includes functionality provided by third parties (eg YouTube). We’ve listed these below. Disabling cookies will probably break the functions offered by third parties:
YouTube
SoundCloud
These cookies help power the video on our site.
Social website cookies
We have included buttons on our site so you can easily ‘Like’ or share our content on social networking sites such as Facebook and Twitter. The plugin we use requires cookies to function.
The privacy implications of this will vary from social network to social network and will depend on the privacy settings you have chosen on those networks.
Anonymous visitor statistics cookies
Analytics programs use cookies to compile website statistics. Unless you explicitly give us your information by filling in a form or calling us, all data that analytics programs collects is stored in an anonymous, aggregate form.
Examples include:
• how visitors reached our website (eg from an advert, from social networks, from Google etc)
• the site usage of visitors to our website (such as the number of pages viewed, time spend on individual pages, the pages visitors leave our site on)
• how often visitors return to our site
• visitor technology (eg browser, operating system, device etc).
These statistics help us make our site as user-friendly as possible, to ensure a good experience for all visitors.
We use:
Google Analytics – a program that helps us measure site usage.
Hotjar – a tool which records visitors’ usage of pages on the site so we can optimise our webpages’ design and usability.
ConvertKit – a database that keeps track of the people we send email marketing to. If you give us your email address using a web form, your activity on this site will be associated with your email in our ConvertKit database.
We believe that the above third-party providers are GDPR-compliant.
Turning cookies off
You can usually switch cookies off by adjusting your browser settings to stop it accepting cookies. Click the name of your preferred browser below to learn how:
Internet Explorer
Mozilla Firefox
Safari
Google Chrome.
Please be aware though that turning off cookies will impair the performance of many websites.
Cookie policy and audit created with the help of Attacat Internet Marketing http://www.attacat.co.uk/. If you would like more information, please contact us.