This Privacy Policy sets out how we, Eric and Elaine OnLife LLC, collect, store and use information about you when you use or interact with our website www.ericandelaine.com (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 23rd November 2020.
Contents
- Summary
- Our details
- Information we collect when you visit our website
- Information we collect when you contact us
- Information we collect when you interact with our website
- Information we collect when you place an order on our website
- How we collect or obtain information about you from third parties
- Disclosure and additional uses of your information
- How long we retain your information
- How we secure your information
- Transfers of your information outside the European Economic Area
- Your rights in relation to your information
- Your right to object to the processing of your information for certain purposes
- Sensitive Personal Information
- Changes to our Privacy Policy
- Children’s Privacy
- California Do Not Track Disclosures
Summary
This section summarizes how we obtain, store, and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
- Data controller: Eric and Elaine OnLife LLC
- How we collect or obtain information about you:
- when you provide it to us (e.g., by contacting us, placing an order on our website, by signing up to our e-newsletter and downloading our content)
- from your use of our website, using cookies and similar technologies, and
- occasionally, from third parties.
- Information we collect name, contact details, payment information (e.g., your credit or debit card details), IP address, information from cookies, information about your computer or device (e.g., device and browser type), information about how you use our website (e.g., which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address), company name or business name (if applicable)), and your answers to online quizzes and assessments we provide.
- How we use your information: for administrative and business purposes (particularly to contact you and process orders you place on our website), to improve our business and website, to fulfill our contractual obligations, to advertise our goods and services, to analyze your use of our website, and about our legal rights and obligations and to provide your answers to our quizzes and assessments.
- Disclosure of your information to third parties: only to the extent necessary to run our business, to fulfill any contracts we enter into with you, where required by law or to enforce our legal rights.
- Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No.
- How long we retain your information: for no longer than necessary, considering any legal obligations we have (e.g., to maintain records for tax purposes), any other legal basis we have for using your information (e.g., your consent, performance of a contract with you or our legitimate interests as a business). For specific retention periods in relation to certain information that we collect from you, please see the main section below entitled How long we retain your information.
- How we secure your information: using appropriate technical and organizational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.
- Use of cookies [and similar technologies]: we use cookies and similar information-gathering technologies, such as web beacons, on our website. For more information, please visit our cookies policy here: ericandelaine.com/cookie-policy.
- Transfers of your information outside the European Economic Area: in certain circumstances, we transfer your information outside of the European Economic Area, including to the following countries: United States. Where we do so, we will ensure appropriate safeguards are in place, including the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield.
- Use of automated decision making and profiling: we do not employ automated decision making and/or profiling.
- Your rights in relation to your information:
- to access your information and to receive information about its use
- to have your information corrected and/or completed
- to have your information deleted
- to restrict the use of your information
- to receive your information in a portable format
- to object to the use of your information
- to withdraw your consent to the use of your information
- to complain to a supervisory authority
- Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.
Our details
The data controller in respect of our website is Eric and Elaine OnLife, LLC of 3613 Goodhope Street, Houston, TX 77021. You can contact the data controller by writing to 3613 Goodhope Street, Houston, TX 77021 or sending an email to info@ericandelaine.com.
The data controller’s representative is J Johnson. You can contact the data controller’s representative by sending an email to info@ericandelaine.com.
If you have any questions about this Privacy Policy, please contact the data controller.
Information we collect when you visit our website.
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
Web server log information
We use a third-party server to host our website called wpengine.com, the privacy policy of which is available here: https://wpengine.com/legal/privacy/
Our server is in the USA, and, accordingly, your information is transferred outside the European Economic Area (EEA). For further information and information on the safeguards used, please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.
Use of website server log information for IT security purposes
We do not access log data from our website server.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
Legal obligation: we have a legal obligation to implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
Legal basis for processing: our and a third party’s legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: we and our third-party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.
Use of website server log information to analyze website use and improve our website
We use the information collected by our website server logs to analyze how our website users interact with our website and its features. For example, we analyze the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit, and the operating system and browser used.
We use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content, and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on pages on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.
Cookies and similar technologies
Cookies are data files that are sent from a website to a browser to record information about users for various purposes.
We use cookies and similar technologies on our website, including essential, functional, analytical, and targeting cookies and web beacons. For further information on how we use cookies, please see our cookies policy, which is available here: www.ericandelaine.com/cookie-policy.
You can reject some or all the cookies we use on or via our website by changing your browser settings or non-essential cookies by using our cookie control tool, but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.
Information we collect when you contact us.
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you send an email to the email address displayed on our website, we collect your email address and any other information you provide in that email (such as your name, telephone number, and the information contained in any signature block in your email).
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to inquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
The reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
We use a third-party email provider to store the emails you send us. Our third-party email provider is Gmail. Their privacy policy is available here: https://policies.google.com/privacy.
Contact form
When you contact us using our contact form, we collect your name, email address, IP address. We also collect any other information you provide to us when you complete the contact form, including any optional information, such as your quiz and assessment answers.
If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form, and we will not receive your inquiry.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to inquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Transfer and storage of your information
Messages you send us via our contact form will be stored outside the European Economic Area on our third-party servers in the USA. Our third-party hosting provider is GoDaddy. Their privacy policy is available here: https://www.godaddy.com/legal/agreements/privacy-policy.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Phone
When you contact us by phone, we collect your phone number, and any information provide to us during your conversation with us.
We do not record phone calls.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation)
Legitimate interest(s): responding to inquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).
Post
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation.
Legitimate interest(s): responding to inquiries and messages we receive and keeping records of correspondence.
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so.
Information we collect when you interact with our website.
We collect and use information from individuals who interact with the features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
Tips and Advice E-Newsletter
When you sign up for our e-newsletter on our website or opt to receive news, offers, and any other information from us by entering their name and email address and clicking subscribe or ticking a box at checkout indicating that you would like to receive our content, we collect your name, email address and any other information you provide.
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you our e-newsletter by signing up to receive it using the steps described above.
Transfer and storage of your information
We use a third-party service, Godaddy, to send out our e-newsletter and administer our mailing list. Their privacy policy is available here: https://www.godaddy.com/legal/agreements/privacy-policy.
Use of web beacons and similar technologies in emails
We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as delivery rates, open rates, and click-through rates. We will only use web beacons in our emails if you have consented to us doing so.
For more information on how we use web beacons in our e-newsletter emails, see our cookies policy, which is available here: www.ericandelaine.com/cookie-policy.
For more information about our third-party mailing list provider and they use web beacons, please see their privacy policy, which is available here: https://www.godaddy.com/legal/privacy-policy.
Registering on our website
When you register and create an account on our website, we collect the following information name, email address, IP address, and any other information you provide to us when you complete the registration form, including any optional information, such as phone number or company name.
If you do not provide the mandatory information required by the registration form, you will not be able to register or create an account on our website.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest: registering and administering accounts on our website to provide access to content and facilitate the running and operation of our business.
Transfer and storage of your information
Information you submit to us via the registration form on our website will be stored outside the European Economic Area on our third-party hosting provider’s servers in the USA. Our third-party hosting provider is GoDaddy. Their privacy policy is available here: https://www.godaddy.com/legal/privacy-policy.
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Information we collect when you place an order on our website.
We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
Information collected when you place an order.
Mandatory information
When you place an order for goods or services on our website, we collect your name, email address, billing address, shipping address, company name (if applicable), and VAT number (if applicable).
If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.
Optional information
We also collect optional information from you, such as your phone number. We also ask you if you would like to receive marketing communications from us. For further information, see ‘Marketing communications’ in this section below.
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Legitimate interests: you consent to us processing any optional information you provide by submitting that information to us.
Information we collect when you place an order on our website.
We collect and use information from individuals who place an order on our website in accordance with this section and the section entitled Disclosure and additional uses of your information.
Information collected when you place an order.
Mandatory information
When you place an order for goods or services on our website, we collect your name, email address, billing address, shipping address, company name (if applicable), and VAT number (if applicable).
If you do not provide this information, you will not be able to purchase goods or services from us on our website or enter into a contract with us.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we need the mandatory information collected by our checkout form to establish who the contract is with and to contact you to fulfil our obligations under the contract, including sending you receipts and order confirmations.
Optional information
We also collect optional information from you, such as your phone number. We also ask you if you would like to receive marketing communications from us. For further information, see ‘Marketing communications’ in this section below.
Legal basis for processing: your consent (Article 6(1)(a) of the General Data Protection Regulation).
Legitimate interests: you consent to us processing any optional information you provide by submitting that information to us.
Processing your payment
After you place an order on our website, you will need to make payment for the goods or services you have ordered. In order to process your payment, we use a third-party payment processor. Your payment will be processed by the third-party payment processor you choose to process your payment via a payment gateway.
The third-party payment processor you choose to process your payment collects, uses, and processes your information, including payment information, in accordance with their privacy policies. You can access privacy policies via the following link(s): https://www.paypal.com/en/webapps/mpp/ua/privacy-full; https://www.godaddy.com/legal/privacy-policy.
Transfer and storage of your information
For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Legal basis for processing: necessary to perform a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: to fulfil your contractual obligation to pay for the goods or services you have ordered from us.
Marketing communications
At checkout, you will have the option of receiving marketing communications from us.
You can opt-out from receiving marketing communications in relation to our goods and which are like those which you purchase from us, by not ticking the tick box.
We will send you marketing communications in relation to similar goods and services if you do not opt-out of receiving them.
Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interests: direct marketing and advertising our products and services.
Transfer and storage of your information
We use a third-party service to administer our mailing list, GoDaddy.
Information you submit to subscribe to our e-newsletter will be stored outside the European Economic Area on our third-party mailing list provider’s servers in the USA. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of web beacons and similar technologies in emails
We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as delivery rates, open rates, and click-through rates. We will only use web beacons in our emails if you have consented to us doing so.
For more information on how we use web beacons in our emails, see our cookies policy, which is available here: www.ericandelaine.com/cookie-policy.
For more information about our third-party mailing list provider and they use web beacons, please see their privacy policy, which is available here: https://www.godaddy.com/legal/privacy-policy.
Our goods and services
You can opt into receiving marketing communications from us in relation to our goods and services by email, text message, phone by ticking a box indicating that you would like to receive such communications.
We will send you marketing communications in relation to our goods and services only if you opt-in to receive them.
Legal basis for processing: consent (Article 6(1)(a) of the General Data Protection Regulation).
Consent: you give your consent to us sending you information about our goods and services by signing up to receive such information in accordance with the steps described above.
Transfer and storage of your information
We use a third-party service to administer our mailing list, GoDaddy.
Information you submit to subscribe to our e-newsletter will be stored outside the European Economic Area on our third-party mailing list provider’s servers in the USA. For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.
Use of web beacons and similar technologies in emails
We use technologies such as web beacons (small graphic files) in the emails we send to allow us to assess the level of engagement our emails receive by measuring information such as delivery rates, open rates, and click-through rates. We will only use web beacons in our emails if you have consented to us doing so.
[For more information on how we use web beacons in our emails, see our cookies policy, which is available here: www.ericandelaine.com/cookie-policy.
For more information about our third-party mailing list provider and they use web beacons, please see their privacy policy, which is available here: https://www.godaddy.com/legal/privacy-policy.
Information collected or obtained from third-parties.
This section sets out how we obtain or collect information about you from third-parties.
Information received from third parties.
Generally, we do not receive information about you from third-parties.
Where we receive information about you in error
If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
Information obtained by us from third parties
In certain circumstances (for example, to verify the information we hold about you or obtain missing information we require to provide you with a service), we will obtain information about you from certain publicly accessible sources, both EU and non-EU, such as the electoral register, Companies House, online customer databases, business directories, media publications, social media, and websites (including your own website if you have one).
Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: where you have entered into a contract or requested that we enter into a contract with you, in certain circumstances, we will obtain information about you from public sources in order to enable us to understand your business and provide services to you or services to a sufficient standard.
For example, we would obtain and/or verify your email address from your website or from a directory where you ask us to send you information by email, but we do not possess the information, or we need to confirm that we have recorded your email address correctly.
Our use of automated decision-making and profiling
We use automated decision making and profiling on our website. We do not consider that this has any legal effect on you or similarly significantly affects you.
You have the right to object to our use of automated decision making and profiling described in this section. You can do that by opting-out of cookies and similar technologies in accordance with the method described in the relevant section below. If you do not want us to process your actual IP address (usually the IP address assigned to you by your Internet Service Provider) when you visit our website, you can use a Virtual Private Network (VPN) or a free service such as Tor.
You can find out more about our use of cookies and similar technologies (including the legal basis on which we use them) and how to opt out from them in our cookies policy, which is available here: www.ericandelaine.com/cookie-policy.
Automated decision making
Automated decision making is decision making by technological means (i.e., by a machine) without human involvement.Use of automated decision making for [display] advertising. We automate the display advertisements containing our products and services on other websites you visit, you based on the fact that you have visited our website using cookies. For further information on the cookies we use, please see our cookies policy which is available here: www.ericandelaine.com/cookie-policy.Logic involved: automatically displaying advertisements to individuals who have visited our website results in increased efficiencies and costs savings for us than manually displaying advertisements or displaying advertisements by different means.Significance and envisaged consequences: cookies will be used to recognize the fact that you have visited our website in order to display advertisements to you (unless you have blocked such cookies) and will collect information about your online behavior.How to object: you can block these cookies by using the cookies control management tool on your site (if you use one). For Google DoubleClick, by opting out of seeing personalized ads by following the instructions here: https://support.google.com/ads/answer/2662922?hl=en-GB]. For further information, please see our cookies policy: www.ericandelaine.com/cookie-policy.ProfilingProfiling is any form of automated processing of your information to evaluate personal aspects about you to analyze or predict things like your performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.Use of profiling for web analytics or web analytics service, Google Analytics uses collects information such as your location (based on your IP address) and your behavior (based on cookies) when you access our website (such as the pages you visit and what you click on). We will only process information from cookies if you have consented to us setting cookies on your computer in accordance with our cookies policy www.ericandelaine.com/cookie-policy..Logic involved: by automatically analyzing and categorizing information such as the location (based on IP address), as well as the behavior and devices of visitors to our website (using cookies), we are able to gain a better understanding of what our website visitors want (in terms of the content of our website and our products), how to improve our website and how to advertise and market our services to them.Significance and envisaged consequences: cookies will be used to track and store information about your behavior and device on our website (unless you have opted out from receiving such cookies) and your location will be analyzed based on your IP address. We may target advertisements based on the level of interest we receive from certain visitors and their behavior on our website.Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).Use of profiling in marketing emails. We use web beacons in our marketing emails to analyze who opens our emails and what actions they take (for example, what they click on). We will only process information from web beacons if you have consented to their use in accordance with our cookies policy (www.ericandelaine.com/cookie-policy).Logic involved: by analyzing how our email recipients respond to our emails, we can improve the content and effectiveness of our emails and gauge who is most interested.Significance and envisaged consequences: your behavior when you open our emails will be tracked using small gif files (web beacons), including open rates and click-through rates.How to object: Contact us via email at info@ericandelaine.com.Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).Legitimate interest: analyzing the level of engagement and effectiveness of our marketing emails and content.Disclosure and additional uses of your information. This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.Disclosure of your information to service providers. We use many third-parties to provide us with services that are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. We do not display the identities of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties to allow us to run and manage our business efficiently.Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.Disclosure of your information to other third partiesWe disclose your information to other third parties in specific circumstances, as set out below.
Providing information to third parties such as Google Inc. Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymized basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/]Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptoutTransfer and storage of your informationInformation collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.Sharing your information with third parties, which are either related to or associated with the running of our business, where it is necessary for us to do so. These third parties include our accountants, advisors, business partners, independent contractors, and insurers. Further information on each of these third parties is set out below.Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest: running and managing our business efficiently.
AccountantsWe share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end-of-year accounts.
AdvisorsOccasionally, we obtain advice from advisors, such as accountants, financial advisors, and lawyers. We will share your information with these third parties only where it is necessary to enable these third parties to be able to provide us with the relevant advice.
Business partners. Business partners are businesses we work with which provide goods and services which are complementary to our own or which allow us to provide goods or services which we could not provide on our own. We share information with our business partners where you have requested services which they provide whether independently from, or in connection with or own services.
Independent contractors. Occasionally, we use independent contractors in our business. Your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them to perform in relation to our business.
Insurers. We will share your information with our insurers where it is necessary to do so, for example in relation to a claim or potential claim we receive or make or under our general disclosure obligations under our insurance contract with them. Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest: running and managing our business effectively. We do not display the identities of the other third parties we may share information with by name for security and competitive reasons. If you would like further information about the identities of such third parties, please contact us directly at info@ericandelaine.com and we will provide you with such information where you have a legitimate reason for requesting it (for example, where we have shared your information with such third-parties).
Sharing your information with a prospective or actual purchaser or seller in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential. Legal basis for processing: legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest(s): sharing your information with a prospective purchaser, seller or similar person to allow such a transaction to take place.Disclosure and use of your information for legal reasons.
Indicating possible criminal acts or threats to public security to a competent authority. If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that fraud or a cybercrime has been committed or if we receive threats or malicious communications towards us or third parties. We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way. Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interests: preventing crime or suspected criminal activity (such as fraud).
In connection with the enforcement or potential enforcement our legal rights. We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.
In connection with a legal or potential legal dispute or proceedings. We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process. Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest(s): resolving disputes and potential disputes.
For ongoing compliance with laws, regulations and other legal requirements. We will use and process your information to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.Legal basis for processing: compliance with a legal obligation (Article 6(1)(c) of the General Data Protection Regulation). Legal obligation(s): legal obligations to disclose information which are part of the laws of the United States of America.Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation). Legitimate interest: where the legal obligations are part of the laws of another country and have not been integrated into the United Kingdom’s legal framework, we have a legitimate interest in complying with these obligations. How long we retain your informationThis section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Server log information: we retain information on our server logs for 12months.
Order information: when you place an order for goods and services, we retain that information for six years following the end of the financial year in which you placed your order, in accordance with our legal obligation to keep records for tax purposes.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 24 further month(s) after which point we will delete your information.E-Newsletter: we retain the information you used to sign up for our e-newsletter for as long as you remain subscribed (i.e. you do not unsubscribe) or if we decide to cancel our e-newsletter service, whichever comes earlier. Criteria for determining retention periods. In any other circumstances, we will retain your information for no longer than necessary, considering the following:
- the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
- whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
- whether we have any legal basis to continue to process your information (such as your consent);
- how valuable your information is (both now and in the future);
- any relevant agreed industry practices on how long information should be retained;
- the levels of risk, cost and liability involved with us continuing to hold the information;
- how hard it is to ensure that the information can be kept up to date and accurate; and
- any relevant surrounding circumstances (such as the nature and status of our relationship with you).
How we secure your information
We take appropriate technical and organizational measures to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:
- only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible;
- using secure servers to store your information;
- verifying the identity of any individual who requests access to information prior to granting them access to information;
- using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website and any payment transactions you make on or via our website;
- only transferring your information via closed system or encrypted data transfers;
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you because of your decision to transmit information to us by such means.
Transfers of your information outside the European Economic Area
Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organization to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
Server log information
Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our third-party hosting company, GoDaddy. You can access their privacy policy here: https://www.godaddy.com/legal/privacy-policy.
Country of storage: USA.
Safeguard(s) used: our third-party hosting provider has self-certified its compliance with the EU-U.S. Privacy Shield.
Contact form
Information you submit to us via our contact form is transferred outside the EEA and stored on our third-party hosting company, GoDaddy. You can access their privacy policy here: https://www.godaddy.com/legal/privacy-policy.
Country of storage: USA.
Safeguard(s) used: our third-party hosting provider has self-certified its compliance with the EU-U.S. Privacy Shield.
E-Newsletter
Information you submit to us when you sign up for our e-newsletter is transferred outside the EEA and stored on our third-party mailing list provider’s servers. Our third-party mailing list provider is: GoDaddy. You can access their privacy policy here: https://www.godaddy.com/legal/privacy-policy.
Country of storage: USA.
Safeguard(s) used: our third-party hosting provider has self-certified its compliance with the EU-U.S. Privacy Shield.
Google Analytics
Information collected by Google Analytics, such as your IP address and actions you take in relation to our website, is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/
Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.
Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: https://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm
Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by sending an email to info@ericandelaine.com:
- to request access to your information and information related to our use and processing of your information;
- to request the correction or deletion of your information;
- to request that we restrict our use of your information;
- to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third-party data controller);
- to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
- to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
- the right not to be subject to a decision based solely on automated processing, including profiling which produces legal effects concerning you or similarly significantly affects you
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/
Further information on your rights in relation to your personal data as an individual
The above rights are provided in summary form only and certain limitations apply to many of these rights. For further information about your rights in relation to your information, including any limitations which apply, please visit the following pages on the ICO’s website:
- https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/; and
- https://ico.org.uk/for-the-public/is-my-information-being-handled-correctly/
You can also find out further information about your rights, as well as information on any limitations which apply to those rights, by reading the underlying legislation contained in Articles 12 to 22 and 34 of the General Data Protection Regulation, which is available here: https://ec.europa.eu/justice/data-protection/reform/files/regulation_oj_en.pdf
Verifying your identity where you request access to your information
Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.
These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorized access to your information.
How we verify your identity
Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.
If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation to be able to verify your identity before we are able to provide you with access to your information.
We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.
Your right to object to the processing of your information for certain purposes
You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by sending an email to info@ericandelaine.com
- to object to us using or processing your information where we use or process it to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e., analyzing or predicting your behavior based on your information) based on any of these purposes; and
- to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).
You may also exercise your right to object to us using or processing your information for direct marketing purposes by:
- clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
- sending an email to info@ericandelaine.com asking that we stop sending you marketing communications or by including the words “OPT-OUT”.
For more information on how to object to our use of information collected from cookies and similar technologies, please see the section entitled How to accept or reject cookies in our cookies policy, which is available here: www.ericandelaine.com/cookie-policy.
Sensitive Personal Information
‘Sensitive personal information’ is information about an individual that reveals their racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic information, biometric information for the purpose of uniquely identifying an individual, information concerning health or information concerning a natural person’s sex life or sexual orientation.
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
Some of the images and details of people referred to on the website have been altered to protect the identity of our coaching clients.
Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
Minor changes to our Privacy Policy
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Major changes to our Privacy Policy or the purposes for which we process your information
Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
Children’s Privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
It is possible that we could receive information pertaining to persons under the age of 18 by the fraud or deception of a third-party. If we are notified of this, as soon as we verify the information, we will, where required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information about persons under the age of 18, please do so by sending an email to info@ericandelaine.com.
California Do Not Track Disclosures
“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on a Do Not Track signal in their browser, the browser sends a message to websites requesting that they do not track the user. For information about Do Not Track, please visit www.allaboutdnt.org
At this time, we do not respond to Do Not Track browser settings or signals. In addition, we use other technology that is standard to the internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to the website. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal. For information on how to opt out from tracking technologies used on our website, see our cookies policy which is available here: www.ericandelaine.com/cookie-policy.