This is the privacy notice of Naomi Dalton. In this document, “I”, “my”, or “me” refer to Naomi Dalton.
I am registered as self-employed in the United Kingdom. Please contact me to request my postal address.
The bases on which I process information about you
The law requires me to determine under which of six defined bases I process different categories of your personal information, and to notify you of the basis for each category.
If a basis on which I process your personal information is no longer relevant then I shall immediately stop processing your data.
If the basis changes then if required by law I shall notify you of the change and of any new basis under which I have determined that I can continue to process your information.
1. Information I process because I have a contractual obligation with you
When you create an account on my website, buy a product or service from me, or otherwise agree to my terms and conditions, a contract is formed between you and me.
In order to carry out my obligations under that contract I must process the information you give me. Some of this information may be personal information.
I may use it in order to:
1.1. verify your identity for security purposes
1.2. sell products to you
1.3. provide you with my services
1.4. provide you with suggestions and advice on products, services and how to obtain the most from using our website
I process this information on the basis there is a contract between us, or that you have requested I use the information before we enter into a legal contract.
Additionally, I may aggregate this information in a general way and use it to provide class information, for example to monitor my performance with respect to a particular service I provide. If I use it for this purpose, you as an individual will not be personally identifiable.
I shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
2. Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse my website or ask me to provide you more information about my business, including my products and services, you provide your consent to us to process information that may be personal information.
Wherever possible, I aim to obtain your explicit consent to process this information, for example, by asking you to agree to my use of cookies.
Sometimes you might give your consent implicitly, such as when you send me a message by e-mail to which you would reasonably expect me to reply.
Except where you have consented to my use of your information for a specific purpose, I do not use your information in any way that would identify you personally. I may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
Only if you have given me explicit permission to do so, I may from time to time pass your name and contact information to selected associates whom I consider may provide services or products you would find useful.
I continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing me here. However, if you do so, you may not be able to use my website or my services further.
5. Information I process because I have a legal obligation
I am subject to the law like everyone else. Sometimes, I must process your information in order to comply with a statutory obligation.
For example, I may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. This may include your personal information.
Specific uses of information you provide to me.
6. Information provided on the understanding that it will be shared with a third party
My website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.
Examples include:
In posting personal information, it is up to you to satisfy yourself about the privacy level of every person who might use it.
I do not specifically use this information except to allow it to be displayed or shared.
I do store it, and I reserve a right to use it in the future in any way I decide.
Once your information enters the public domain, I have no control over what any individual third party may do with it. I accept no responsibility for their actions at any time.
Provided your request is reasonable and there is no legal basis for me to retain it, then at my discretion I may agree to your request to delete personal information that you have posted. You can make a request by contacting me at naomi at naomidalton dot com.
7. Information relating to your method of payment
Payment information is never taken by me or transferred to me either through my website or otherwise. My employees and contractors never have access to it.
At the point of payment, you are transferred to a secure page on the website of Paypal / Stripe or some other reputable payment service provider. That page may be branded to look like a page on my website, but it is not controlled by me.
8. Sending me a message
When you contact me, whether by telephone, through our website or by e-mail, I collect the data you have given to me in order to reply with the information you need.
I record your request and my reply in order to increase the efficiency of my business.
I keep personally identifiable information associated with your message, such as your name and email address so as to be able to track my communications with you to provide a high quality service.
9. Complaining
When I receive a complaint, I record all the information you have given to me.
I use that information to resolve your complaint.
If your complaint reasonably requires me to contact some other person, I may decide to give to that other person some of the information contained in your complaint. I do this as infrequently as possible, but it is a matter for my sole discretion as to whether I do give information, and if I do, what that information is.
I may also compile statistics showing information obtained from this source to assess the level of service I provide, but not in a way that could identify you or any other person.
10. Affiliate and business partner information
This is information given to me by you in your capacity as my affiliate or as a business partner.
It allows me to recognise visitors that you have referred to me, and to credit to you commission due for such referrals. It also includes information that allows me to transfer commission to you.
The information is not used for any other purpose.
I undertake to preserve the confidentiality of the information and of the terms of our relationship.
I expect any affiliate or partner to agree to reciprocate this policy.
Use of information I collect through automated systems when you visit our website
11. Cookies
Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.
This website uses cookies. They are placed by software that operates on my servers, and by software operated by third parties whose services I use.
When you first visit our website, I ask you whether you wish me to use cookies. If you choose not to accept them, I shall not use them for your visit except to record that you have not consented to their use for any other purpose.
If you choose not to use cookies or you prevent their use through your browser settings, you will not be able to use all the functionality of our website.
I use cookies in the following ways:
11.1 to track how you use my website
11.2 to record whether you have seen specific messages I display on my website
11.3 to keep you signed in the site if you have an account
11.4 to record your answers to surveys and questionnaires on my site while you complete them
11.5 to record the conversation thread during a live chat with me or my support team
12. Personal identifiers from your browsing activity
Requests by your web browser to my servers for web pages and other content on our website are recorded.
I record information such as your geographical location, your Internet service provider and your IP address. I also record information about the software you are using to browse our website, such as the type of computer or device and the screen resolution.
I use this information in aggregate to assess the popularity of the webpages on my website and how I perform in providing content to you.
If combined with other information I know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to my website.
13. Our use of re-marketing
Re-marketing involves placing a cookie on your computer when you browse my website in order to be able to serve to you an advert for our products or services when you visit some other website.
I may use a third party to provide me with re-marketing services from time to time. If so, then if you have consented to our use of cookies, you may see advertisements for my products and services on other websites.
Disclosure and sharing of your information
14. Information we obtain from third parties
Although I do not disclose your personal information to any third party (except as set out in this notice), I sometimes receive data that is indirectly made up from your personal information from third parties whose services I use.
15. Data may be processed outside the UK and the European Union
My websites are hosted with HostGator.
I may also use outsourced services in countries outside the UK and the European Union from time to time in other aspects of my business.
Accordingly, data obtained within the UK or any other country could be processed outside the European Union.
For example, some of the software my website uses may have been developed in the United States of America or in Australia.
I use the following safeguards with respect to data transferred outside the European Union:
15.1. the processor is within the same corporate group as my business or organisation and abides by the same binding corporate rules regarding data processing.
15.2. the data protection clauses in my contracts with data processors include transfer clauses written by or approved by a supervisory authority in the European Union
15.3. I comply with a code of conduct approved by a supervisory authority in the European Union
15.4. I am certified under an approved certification mechanism as provided for in the GDPR
15.5. both my organisation and the processor are public authorities between whom there is either a legally binding agreement or administrative arrangements approved by a supervisory authority in the European Union relating to protection of your information
Access to your own information
16. Access to your personal information
16.1. At any time you may review or update personally identifiable information that I hold about you, by contacting me at naomi at naomidalton dot com
16.2. After receiving the request, I will tell you when I expect to provide you with the information, and whether I require any fee for providing it to you.
17. Removal of your information
If you wish me to remove personally identifiable information from my website, you may contact me at naomi at naomidalton dot com.
This may limit the service I can provide to you.
18. Verification of your information
When I receive any request to access, edit or delete personal identifiable information I shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Other matters
19. Use of site by children
19.1. I do not sell products or provide services for purchase by children, nor do I market to children.
19.2. If you are under 18, you may use my website only with consent from a parent or guardian
20. Encryption of data sent between us
I use Secure Sockets Layer (SSL) certificates to verify my identity to your browser and to encrypt any data you give me.
Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.
21. How you can complain
If you are not happy with this privacy policy or if you have any complaint then you should tell me by email at naomi at naomidalton dot com.
21.1. If a dispute is not settled then I hope you will agree to attempt to resolve it by engaging in good faith with me in a process of mediation or arbitration.
21.2. If you are in any way dissatisfied about how I process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/
22. Retention period for personal data
Except as otherwise mentioned in this privacy notice, I keep your personal information only for as long as required by me:
22.1. to provide you with the services you have requested;
22.2. to comply with other law, including for the period demanded by my tax authorities;
22.3. to support a claim or defence in court.
23. Compliance with the law
My privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which I aim to do business. If you think it fails to satisfy the law of your jurisdiction, I should like to hear from you.
However, ultimately it is your choice as to whether you wish to use my website.
24. Review of this privacy policy
I may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on my website on the day you use my website. I advise you to print a copy for your records.
If you have any question regarding my privacy policy, please contact me at naomi at naomidalton dot com.
