I respect your privacy and am committed to protecting your personal data. This privacy notice will inform you as to how I look after your personal data and tell you about your privacy rights and how the law protects you.
This privacy notice was last updated on 28 January 2020.
1. IMPORTANT INFORMATION AND WHO I AM
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Craig McFarlane (referred to as “I”, “me” or “my” in this privacy notice) collects and processes your personal data. It is important that you read this privacy notice together with any other privacy notice or fair processing notice I may provide on specific occasions when I am collecting or processing personal data about you so that you are fully aware of how and why I am using your data. This privacy notice supplements the other notices and is not intended to override them.
For some services I make decisions on how personal information is used in the context of a service (Craig McFarlane is a controller of personal information in this case), and for other services I will only use personal information as instructed by my clients (Craig McFarlane is a processor of personal information in this case).
I am the data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights please contact me using the details set out below.
Data Privacy Manager
2/2 54 Deanston Drive
Glasgow, G41 3AL
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). I would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact me in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM ME OF CHANGES
On 25 May 2018 the General Data Protection Regulation (GDPR) came into effect, and applies to all handling of personal data across Europe. I may change this privacy notice from time to time in order to reflect the changes in the law and/or my privacy practices. I encourage you to check this privacy notice for changes whenever you visit my website – https://www.craigmcfarlane.co.uk/
It is important that the personal data I hold about you is accurate and current. Please keep me informed if your personal data changes during your relationship with me.
My website (https://www.craigmcfarlane.co.uk/) 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. I do not control these third-party websites and am not responsible for their privacy statements. When you leave my website, I encourage you to read the privacy notice of every website you visit.
- THE DATA I COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
I may collect, use, store and transfer different kinds of personal data about you which I have grouped together follows:
- Identity Data includes name, date of birth and gender.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Marketing and Communications Data includes your preferences in receiving marketing from me and my third parties and your communication preferences.
- Special Categories of Personal Data: I may in certain circumstances collect Special Categories of Personal Data about you (this 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).
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where I need to collect personal data by law, or under the terms of a contract I have with you and you fail to provide that data when requested, I may not be able to perform the contract I have or am trying to enter into with you (for example, to provide you with my services). In this case, I may have to cancel a service you have with me but I will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
I use different methods to collect data from and about you including through:
- Direct interactions. You may give me your Identity, Contact and Financial Data by corresponding with me in person or by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for my services;
- subscribe to my service or publications; or
- request marketing to be sent to you.
4. HOW I USE YOUR PERSONAL DATA
I will only use your personal data when the law allows me to. Most commonly, I will use your personal data in the following circumstances:
- Where I need to perform the contract I am about to enter into or have entered into with you.
- Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where I need to comply with a legal or regulatory obligation. I reserve the right to share your information with law enforcement or public authorities if legally required to do so, or to prevent security, fraud or technical issues.
To find out more about the types of lawful basis that I will rely on to process your personal data please see the bottom of this privacy notice.
PURPOSES FOR WHICH I WILL USE YOUR PERSONAL DATA
I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If I need to use your personal data for an unrelated purpose I will notify you and I will explain the legal basis which allows me to do so. I may require use your personal data for the following purposes:
- To manage your relationship with me;
- To provide you with the services you have requested; and
- If you allow me, for marketing purposes.
I strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you tell me I can, I may also use your personal information to provide you with information about services, events, promotions and offers that may be of interest to you.
You can ask me or third parties to stop sending you marketing messages at any time or by contacting me at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to me as a result of a service provided to you.
What is a cookie?
Cookies are text files containing small amounts of information that are downloaded to your personal computer, mobile or other device when you first visit a website. The next time you visit that website, any relevant cookies are sent back to the website, so that the site knows you have been there before. Cookies help you to navigate between different website pages efficiently, remembering your preferences and generally improving the user experience.
CHANGE OF PURPOSE
I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact me.
If I need to use your personal data for an unrelated purpose, I will notify you and I will explain the legal basis which allows me to do so.
Please note that I may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
I may have to share your personal data with selected third parties to facilitate my service, to provide the service on my behalf, to perform service-related services or to assist me in analysing how my service is used.
I require all third parties to respect the security of your personal data and to treat it in accordance with the law. I do not allow my third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with my instructions.
6. INTERNATIONAL TRANSFERS
I do not transfer your personal data outside the European Economic Area (EEA).
7. DATA SECURITY
I 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, I limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on my instructions and they are subject to a duty of confidentiality.
I 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 I am legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
I will only retain your personal data for as long as necessary to fulfil the purposes I collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.
In most circumstances, I will hold your personal data for a period of 24 months, or until none of the following lawful justifications for holding your data apply.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- 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.
If you wish to exercise any of the rights set out above, please contact me.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances.
WHAT I MAY NEED FROM YOU
I may need to request specific information from you to help me 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. I may also contact you to ask you for further information in relation to your request to speed up my response.
TIME LIMIT TO RESPOND
I try to respond to all legitimate requests within one month. Occasionally it may take me longer than a month if your request is particularly complex or you have made a number of requests. In this case, I will notify you and keep you updated.
Legitimate Interest means the interest of my business in conducting and managing my business to enable me to give you the best service/product and the best and most secure experience. I make sure I consider and balance any potential impact on you (both positive and negative) and your rights before I process your personal data for my legitimate interests. I do not use your personal data for activities where my interests are overridden by the impact on you (unless I have your consent or are otherwise required or permitted to by law). You can obtain further information about how I assess my legitimate interests against any potential impact on you in respect of specific activities by contacting me.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that I am subject to.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data I hold about you and to check that I am lawfully processing it.
Request correction of the personal data that I hold about you. This enables you to have any incomplete or inaccurate data I hold about you corrected, though I may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask me to delete or remove personal data where there is no good reason for me continuing to process it. You also have the right to ask me to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where I may have processed your information unlawfully or where I am required to erase your personal data to comply with local law. Note, however, that I may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where I am relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where I am processing your personal data for direct marketing purposes. In some cases, I may demonstrate that I have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask me to suspend the processing of your personal data in the following scenarios: (a) if you want me to establish the data’s accuracy; (b) where my use of the data is unlawful but you do not want me to erase it; (c) where you need me to hold the data even if I no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to my use of your data but I need to verify whether I have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. I will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for me to use or where I used the information to perform a contract with you.
Withdraw consent at any time where I am relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, I may not be able to provide certain products or services to you. I will advise you if this is the case at the time you withdraw your consent.
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