This Privacy Notice sets out the details of how Siobhan Murray (“we”, “us”, “our”) collects and processes your personal data through its website located at www.twistingthejar.com.
For the purposes of this Notice, personal data means any information that can be used to identify an individual whether directly or indirectly.
Please read through the content of this Privacy Notice carefully and ensure that you understand it. If you do not understand the content of this Privacy Notice or do not accept or agree with it then you must stop using the website at www.twistingthejar.com immediately.
By accessing the website at www.twistingthejar.com and providing us with your personal data you are warranting that you are over 13 years of age.
What personal data do we process, why do we process it, and how do we collect it
We may process personal data that you provide to us by subscribing to our newsletter or email list, requesting information through our contact form, or by any other communication via email, text or through our website or other online platforms and social media channels.
(please refer to the section on cookies for further information).
We may also process data received from third parties such as Google, Facebook or other analytic or advertising providers based outside of the EU, or PayPal, Stripe or other payment processing providers and search engines.
When we process your personal data, we will comply with the relevant data protection laws and principles, which means that your data will be used lawfully, fairly and in a transparent way, kept securely and only for as long as necessary for the purposes we have told you about.
The types of personal data which we process will vary depending on your own specific circumstances but typically can include:
· Personal Information, which may include your name, date of birth, email address, phone number, business contact details, correspondence address, IP address. We shall process this data for the purposes of communicating with you and keeping our records on the lawful grounds of legitimate interest;
· Customer or Client information, should you purchase goods and/or services from us then we may process information in connection with your purchase, and the supply of that purchase, as well as keeping appropriate records. Such information may include your Personal Information, billing address, delivery address, credit card or other payment details and we shall process it on contractual grounds;
· User Information, this may include comments or statements that you may make or post via our website, online platforms or social media channels, images, documents or videos that you share on or through our website or through any of our pages or other online platforms, and information concerning your use of our website or other online platforms such as your browser information, pixel ID, page views, pages visited, number of visits and where appropriate log-in details. We shall process this information to analyse and monitor usage and content of our website and other platforms and channels to ensure the content is relevant to you, to support our administration and record keeping requirements, and to maintain security of our systems on legitimate interest grounds;
· Promotional Information, this may include information you provide in connection with any promotions, marketing or advertising from us or our third parties. We shall use this information to provide relevant offers and advertisements, competitions and promotions and other free resources and to monitor our promotional activity, keep records and compile analytics on legitimate interest grounds.
We may also process your personal data to deliver or send relevant advertisements to you through our website and other online platforms and to analyse the success and effectiveness of such adverts for the purposes of promoting and growing our business.
In accordance with the Privacy and Electronic Communications Regulations (PECR) we may also send you relevant advertisements or marketing information if you:
1. have ever purchased or enquired about our products or services; and
2. at the time of your purchase or enquiry you agreed to receive advertising or marketing information from us and you have not opted out from receiving that information;
Where we contact you through email we shall ensure that our emails clearly display the location of the sender and include clear options for you to opt-out from receiving contact from us in accordance with the CAN-SPAM act.
We do not collect any sensitive data about you. Sensitive data includes data relating to your health, race or ethnic origin, religious or political beliefs, trade union membership, genetics, biometrics, sex life or sexual orientation. We do not process any data relating to criminal offences and convictions.
We shall only collect and process your personal data for purposes that are clearly outlined prior to you providing us with your data, or for a legitimate reason.
Whenever we process your personal data we do so on the basis of a lawful condition this will either be because you have given your consent for us to process your data, where we are under a contractual or legal obligation, or where it is in our legitimate interests to do so.
We do not carry out automated decision making or any type of automated profiling.
It is very important to us that the information we hold about you is complete, accurate and up to date. If at any time your personal details change, please let us know by emailing us at [email protected] so we can update our records.
Disclosure of personal data
We use the following external service providers to support our business and may share your personal data with those third parties:
We understand that all of these third parties have appropriate technical and security processes in place to protect your data.
We may also share your personal data as follows:
1. Where it is necessary for external service providers who have been engaged by us to assist in the provision of services to our clients and customers;
2. Where it is required by our professional support teams;
3. Where we are required by a government body or legal obligation or to protect our rights;
4. Where it is required in connection with the sale or purchase of any business or assets;
5. With any other member or company of our group;
Where we have outsourced a function or activity to an external service provider we will only disclose personal data that the service provider needs to undertake that function or activity, and we require external service providers to agree to keep your personal data secure in accordance with the relevant law.
We agree not to share your personal data with any third party for that third party’s marketing
purposes unless we have obtained your consent to do so.
Transfer of personal data
Our website is located within the Republic of Ireland and we comply with the Internet laws applicable to the Republic of Ireland which includes the General Data Protection regulation.
Your data will be processed within the Republic of Ireland.
We may also transfer your data to a third-party service provider which requires your data to be transferred outside of the EU. Where your data is transferred outside of the EU by our third-party service providers we understand that they comply with the following standards relating to the security of your personal data.
1. Infusionsoft use the EU Model Contract which governs the lawful transfer of data from the EEA to countries outside of the EEA. In respect of any payment or financial information Infusionsoft also complies with the Payment Card Industry Data Security Standards;
2. Facebook complies with the General Data Protection Regulation and is certified under the Privacy shield for data transfers;
3. Google complies with the General Data Protection Regulation and is certified under the Privacy shield for data transfers. Google also complies with the Payment Card Industry Data Security Standards;
4. PayPal relies on Binding Corporate Rules approved by competent Supervisory authorities;
5. Stripe is certified under the EU-US Privacy Shield as well as EU Standard Contractual Clauses and Binding Corporate Rules.
Where we transfer data to parties not listed above that are outside of the EEA then we will ensure that at least one of the following conditions is met:
1. You have given your express consent;
2. The country has an approved adequate level of protection for personal data;
3. It is legally required;
4. It is authorised by the relevant data protection authority;
We take the protection of your personal data seriously and have taken suitable and reasonable steps to protect the personal data we hold from misuse, loss, unauthorised access, and any modification or disclosure.
We limit access to your personal data to those employees, agents, contractor or third parties who have a business need to know. They will only process your data on our instructions and must keep it confidential.
If you are submitting personal data over the internet that you wish to remain private, please note that while attempts are made to secure information transmitted to this site, there are inherent risks in transmitting information across the internet. If you prefer, you can contact us by alternative means using phone or mail.
We will not keep your personal data for longer than is required with regard to the purpose for which it was collected by us or provided by you including any legal or record keeping requirements and will take reasonable steps to destroy or permanently de-identify your personal data when it is no longer required.
Your rights in relation to the data we hold
You have rights in relation to your personal data these include the right to access and receive a copy of your personal data, to ask us to correct any errors, to erase your personal data, to restrict how your information is processes.
Where you have provided your consent for us to process your personal data you can withdraw that consent at any time. Should you wish to do so please contact us at [email protected].
If you are not happy with how we process your personal data you have the right to lodge a complaint with the Information Commissioners Office (ICO), the Irish supervisory authority for data protection issues.
Links to other sites
The website at www.twistingthejar.com may contain links to other sites. We are not responsible for the privacy practices of those web sites and have no knowledge of whether cookies or other tracking devices are used on any such linked sites.
If you have any concerns regarding the privacy of your information you should ensure you are aware of the privacy policies of those sites before disclosing any personal information.
A cookie is a small file of data stored on your computer or mobile device. It collects and records information about how you use our website such as the particular web pages you visit and the information you access. Cookies can also be used to collect details such as your Internet service provider, operating system, browser type and to analyse traffic as well as for advertising and marketing purposes.
You have control over what cookies you accept. You can choose to block all cookies and you are also able to delete all cookies from your browser. You can make your choices by altering your browser settings. You should be aware that if you alter your browser settings to block or delete cookies then you may not be able to access certain areas or features of our website and some parts of the site may not display correctly.
What cookies do we use?
We use First-party and Third-party cookies. First-party cookies are cookies which are directly placed by us and are used only by us. These may include:
1. Session cookies – this is a temporary cookie which is not stored once your browser is closed. These cookies are typically used to support your use of our site but without personally identifying you or collecting any of your personal data;
2. Persistent cookies – these cookies are stored once your browser is closed. These cookies are used to enhance your use and experience of our site;
3. Strictly necessary cookies – these cookies are essential for the operation of our site and we shall use these where they are necessary for us to provide you with the products or services that you may require;
4. Experience cookies – these cookies provide us with information which helps us to monitor the user experience and performance of our site and optimise our pages. The data collected by these cookies is anonymous.
5. Marketing and promotional cookies – these cookies record your use of our site including the pages you have visited and any links you may have followed. We use these cookies to make any promotions, marketing or advertising more relevant and valuable to you.
6. Functionality cookies – these cookies record the choices you make while using our site and may record the products, services or videos you access. The data collected by these cookies is anonymous.
Third-Party cookies are those placed by websites, services and/or parties other than us that may advertise or display information or links on our site. We have no control over these cookies.
It is recommended that you keep your internet browser and your operating system up to date and that you consult the help and guidance of a professional or the manufacturer of your computer of device in the event you have any questions or are unsure about your privacy settings.
If you have any questions about this Privacy Notice or require more information concerning our privacy practices please contact Siobhan – [email protected]
Contact Name: Siobhan Murray
Address: 40 Eaton Square, Terenure, Dublin 6W, Ireland
Email Address: [email protected]
Changes to this Privacy Notice
This Privacy Notice is accurate as at July 2018. We reserve the right to alter or amend it without notice. Should the Privacy Notice be altered, the new policy will be posted on the website at www.twistingthejar.com.
Your first use of our website after the date of any amendments or alterations will constitute your acceptance of such changes therefore we recommend you review this Privacy Notice regularly to keep informed of any changes.