Website Privacy Notice

Read our company website privacy notice which is compliant with General Data Protection Regulation
(GDPR)

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your
use of our site or sites owned and operated by (Joanne Thomson and https://joanne-thomslon.com)
( or service providers we use ) , including any information you may provide through our site when you
purchase a product or service, sign up to our newsletter or take part in a prize draw or competition.
By providing us with your data, you warrant to us that you are over 13 years of age.
(Joanne Thomson) is the data controller and we are responsible for your personal data
(referred to as “we”, “us” or “our” in this privacy notice).
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.
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 submitting a support ticket by (jo@joanne-thomson.com)

2. WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised
data.
We may process certain types of personal data about you as follows:
Identity Data may include your first name, maiden name, last name, username, marital status, title, date of
birth and gender.
Contact Data may include your billing address, delivery address, email address and telephone numbers.
Financial Data may include your bank account and payment card details.
Transaction Data may include details about payments between us and other details of purchases made by
you.
Technical Data may include your login data, internet protocol addresses, browser type and version, browser
plug-in types and versions, time zone setting and location, operating system and platform and other
technology on the devices you use to access this site.
Profile Data may include your username and password, purchases or orders, your interests, preferences,
feedback and survey responses.
Usage Data may include information about how you use our website, products and services.
Marketing and Communications Data may include your preferences in receiving marketing communications
from us and our third parties and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity
and as such in itself is not personal data. An example of this is where we review your Usage Data to work out
the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your
personal data so that you can be identified from it, then it is treated as personal data.
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.

3. HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating
with us by post, phone, email or otherwise, including when you:
order our products or services;
create an account on our site;
subscribe to our service or publications;
request resources or marketing be sent to you;
enter a competition, prize draw, promotion or survey; or
give us feedback.
Automated technologies or interactions: As you use our site, we may automatically collect Technical Data
about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server
logs and similar technologies. We may also receive Technical Data about you if you visit other websites that
use our cookies. Please see our ( LINK TO YOUR cookie policy for further details.)
Third parties or publicly available sources: We may receive personal data about you from various third
parties and public sources as set out below:
Technical Data from the following parties:
analytics providers such as (WHO YOU USE EXAMPLE: Google) based outside the EU;
analytics providers such as (WHO YOU USE EXAMPLE:Facebook) based outside the EU;
analytics providers such as (ANY OTHER SERVICE YOU USE FOR EXAMPLE CLICKFUNNELS ETC)
based outside the EU;
advertising networks [such as [EXAMPLES Facebook/Google/Youtube/Instagram/Twitter/Hotjar/
Also Re-targeting services provided by these companies] based [inside OR outside] the EU]; search
information providers Google based [inside OR outside] the EU].
Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as
[AS AN EXAMPLE PAYPAL] based [inside ORoutside] the EU].
Identity and Contact Data from data brokers or aggregators based [inside OR outside] the EU].
Identity and Contact Data from publicly available sources such as ( EXAMPLE FOR UK RESIDENTS
Companies House and the Electoral Register based inside the EU.)

4. HOW WE USE YOUR PERSONAL 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.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in
relation to sending marketing communications to you via email or text message. You have the right to
withdraw consent to marketing at any time by clicking on our Unsubscribe link at the bottom of our email
communications or by submitting a support ticket by (jo@joanne-thomson.com)
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on
which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for
which we are using your data. Please submit a support ticket by if you need (jo@joanne-thomson.com) details about the specific legal ground we are relying on to process your
personal data where more than one ground has been set out in the table below.
(a) Identity
(b) Contact
To register you as a new Performance of a contract with you
customer
Purpose/Activity Type of data Lawful basis for processing
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
(a) Performance of a contract with
you
(b) Necessary for our legitimate
interests to recover debts owed to us
To process and deliver your
order including:
(a) Manage payments, fees and
charges
(b) Collect and recover money
owed to us
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Communications
(a) Performance of a contract with
you
(b) Necessary to comply with a legal
obligation
(c) Necessary for our legitimate
interests to keep our records updated
and to study how customers use our
products/services
To manage our relationship with
you which will include:
(a) Notifying you about changes
to our terms or privacy policy
(b) Asking you to leave a review
or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(b) Necessary for our legitimate
interests to study how customers use
our products/services, to develop
them and grow our business
To enable you to partake in a
prize draw, competition or
complete a survey
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate
interests for running our business,
provision of administration and IT
services, network security, to prevent
fraud and in the context of a business
reorganisation or group restructuring
exercise
(b) Necessary to comply with a legal
obligation
To administer and protect our
business and our site
(including troubleshooting,
data analysis, testing, system
maintenance, support,
reporting and hosting of data)
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Communications
(f) Technical
Necessary for our legitimate interests
to study how customers use our
products/services, to develop them, to
grow our business and to inform our
marketing strategy
To deliver relevant content
and advertisements to you
and measure and understand
the effectiveness of our
advertising
Marketing communications
You will receive marketing communications from us if you have:
i. requested information from us or purchased goods or services from us; or
ii. if you provided us with your details and ticked the box at the point of entry of your details for us to send
you marketing communications; and
iii. in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for
marketing purposes.
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 by submitting a support ticket by (YOUR SUPPORT URL
OR EMAIL ADDRESS) at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided
to us as a result of a product/service purchase, warranty registration, product/service experience or other
transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original purpose. If
you wish to find out more about how the processing for the new purpose is compatible with the original
purpose, please submit a support ticket by (YOUR SUPPORT URL OR EMAIL ADDRESS)
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data,
we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted
by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table
in paragraph 4 above:
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking,
legal, insurance and accounting services.
(EXAMPLE FOR UK RESIDENTS HM Revenue & Customs, regulators and other authorities based
in the United Kingdom) and other relevant jurisdictions who require reporting of processing activities in
certain circumstances.
(a) Technical
(b) Usage
Necessary for our legitimate interests
to define types of customers for our
products and services, to keep our
site updated and relevant, to develop
our business and to inform our
marketing strategy
To use data analytics to
improve our website,
products/services, marketing,
customer relationships and
experiences
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests
to develop our products/services and
grow our business
To make suggestions and
recommendations to you
about goods or services that
may be of interest to you
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

We share your personal data with our approved service suppliers, some of which are outside the European
Economic Area (EEA).
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 implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of
protection for personal data by the European Commission; 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
Where we use providers based in the United States, we may transfer data to them if they are part of the EUUS
Privacy Shield which requires them to provide similar protection to personal data shared between the
Europe and the US.
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.
Please contact us by submitting a support ticket at (YOUR SUPPORT URL OR EMAIL ADDRESS) if you
want further information on the specific mechanism used by us when transferring your personal data out of
the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally
lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your
personal data to those employees, agents, contractors and other third parties who have a business need to
know such data. They will only process your personal data on our instructions and they are subject to a duty
of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and
any applicable regulator of a breach where we are legally required to do so.

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.
To determine the appropriate retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes for which we process your personal data and whether we can achieve those
purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and
Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with
you) for research or statistical purposes in which case we may use this information indefinitely without
further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.
These include the right to:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right 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 contact us by submitting a support ticket at
(YOUR SUPPORT URL OR EMAIL ADDRESS)
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. Alternatively,
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 and keep you updated.

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 ( LINK TO
COOKIE POLICY PAGE)

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