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KIRSTY PARTRIDGE ART LIMITED
Privacy Policy


Introduction
Kirsty Partridge Art Limited (collectively referred to as "we", "us" or "our" in this Privacy Policy) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit https://kirstypartridge.com (our website) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Important information and who we are

Purpose of this privacy policy
This Privacy Policy aims to give you information on how we collect and process your personal data through your use of our website, including any data you may provide through this website when you sign up to any of our courses or for any of our resources, subscribe to be a member of our website or take part in any challenges we run through the website.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this Privacy Policy together with any other privacy notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.


Controller
We are the controller and responsible for your personal data.
Our customer service team is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights please contact us using the details set out below.


Contact details
If you have any questions about this Privacy Policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: Kirsty Partridge Art Limited
Email address: [email protected]
Postal address: Fulford House, Newbold Terrace, Leamington Spa, Warwickshire, United Kingdom, CV32 4EA
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes
We keep our Privacy Policy under regular review.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third party links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
 

2. The data we 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).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data, which includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data, which includes billing address, delivery address, email address and telephone numbers.
  • Financial Data, which includes bank account and payment card details.
  • Transaction Data, which includes details about payments to and from you and other details of courses and resources you have purchased from us.
  • Technical Data, which 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 our website.
  • Profile Data, which includes your username and password, your profile picture, purchases or orders made by you, your interests, preferences, pictures and other content you upload in the Members Area of our website, feedback and survey responses.
  • Usage Data, which includes information about how you use our website and courses and resources.
  • Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any 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) nor do we collect any information about criminal convictions and offences unless you are a member of our website and choose to share any such data about yourself by uploading, posting or otherwise sharing this in chat room functions of the Members Area of our website. We recommend that you carefully consider whether you wish to post or share any Special Categories of Personal Data about you on the Members Area of our website before doing so.

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with access to our resources or register you for one of our courses). In this case, we may have to cancel a contract you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?
We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity Data, Contact Data, Financial Data, Profile Data, Usage Data and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for and/or purchase any of our courses and/or resources;
    • use any of our resources, take part in any of our courses and/or share/upload any content on the Members Area of our website;
    • create an account on our website;
    • subscribe to become a member of our website;
    • request marketing to be sent to you;
    • enter a challenge, promotion or survey; or
    • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website and/or our courses, resources and/or Members Area, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
    • Technical Data and Usage Data from the following parties:
      • analytics providers such as Google based outside the UK; and
      • advertising networks [such as Facebook based outside the UK].
      • [search information providers such as Google and Facebook, both based outside the UK.
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based outside the UK.
    • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Please see section 10 below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

  1. Purpose/Activity: To register you as a new customer

    • Type of Data: (a) Identity, (b) Contact
    • Lawful Basis for Processing: Performance of a contract with you

  2. Purpose/Activity: To enable you to subscribe to become a member of our website

    • Type of Data: (a) Identity, (b) Contact, (c) Profile
    • Lawful Basis for Processing: Performance of a contract with you

  3. Purpose/Activity: To enable you to use any of our resources, take part in any of our courses and/or share/upload any content on the Members Area of our website

    • Type of Data: (a) Identity, (b) Contact, (c) Profile, (d) Usage
    • Lawful Basis for Processing: (a) Performance of a contract with you, (b) Necessary for our legitimate interests (for running our business)

  4. Purpose/Activity: To process and deliver your order, including managing payments, fees and charges, collecting and recovering money owed to us

    • Type of Data: (a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications
    • Lawful Basis for Processing: (a) Performance of a contract with you, (b) Necessary for our legitimate interests (to recover debts due to us)

  5. Purpose/Activity: To manage our relationship with you, including notifying you about changes to our terms or Privacy Policy, asking you to leave a review or take a survey

    • Type of Data: (a) Identity, (b) Contact, (c) Profile, (d) Marketing and Communications
    • Lawful Basis for Processing: (a) Performance of a contract with you, (b) Necessary to comply with a legal obligation, (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)

  6. Purpose/Activity: To enable you to partake in a prize draw, challenge or complete a survey

    • Type of Data: (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications
    • Lawful Basis for Processing: (a) Performance of a contract with you, (b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)

  7. Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

    • Type of Data: (a) Identity, (b) Contact, (c) Technical
    • Lawful Basis for Processing: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), (b) Necessary to comply with a legal obligation

  8. Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

    • Type of Data: (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications, (f) Technical
    • Lawful Basis for Processing: Necessary for our legitimate interests (to study how customers use our resources and courses, to develop them, to grow our business and to inform our marketing strategy)

  9. Purpose/Activity: To use data analytics to improve our website, resources, courses, marketing, customer relationships and experiences

    • Type of Data: (a) Technical, (b) Usage
    • Lawful Basis for Processing: Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

  10. Purpose/Activity: To make suggestions and recommendations to you about resources or courses that may be of interest to you

    • Type of Data: (a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile, (f) Marketing and Communications
    • Lawful Basis for Processing: Necessary for our legitimate interests (to develop our service offering and grow our business)

  11. Purpose/Activity: To include your feedback about us, our resources and/or courses on our website and in other promotional material

    • Type of Data: (a) Identity, (b) Usage, (c) Profile
    • Lawful Basis for Processing: Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business, to promote our resources and courses and to inform our marketing strategy)

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us, purchased (free or paid for) courses and/or resources from us or subscribed to be a member of our website and you have not opted out of receiving that marketing.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.

COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we 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
We may share your personal data with the parties set out below for the purposes set out in the table above.

  • Service providers acting as processors based outside the UK who provide IT and system administration services, such as our website provider, Kajabi and our payment provider, Stripe.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
  • Google Analytics and Facebook based outside of the UK who provide us with analytics and advertising services to help us better understand website traffic and user behaviour.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our 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 our instructions.

6. International transfers
Some of our external third parties are based outside the UK, so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

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

8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
We are happy to provide you with details of the periods of time for which we retain different aspects of your personal data if you request this information from us.
In some circumstances you can ask us to delete your data: please see section 9 below for further information on this.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
• Your right of access – (commonly known as a "data subject access request") you have the right to ask us for copies of your personal information and to check that we are lawfully processing it.
• Your right to rectification/correction – you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete, though we may need to verify the accuracy of the new data you provide to us.
• Your right to erasure – you have the right to ask us to erase your personal information in certain circumstances. You also have the right to ask us to delete or remove your personal data where you have successfully exercised

• your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
• Your right to restriction of processing – you have the right to ask us to restrict the processing of your personal information in certain circumstances.
• Your right to object to processing – you have the right to object to the processing of your personal information where we are 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.
• Your right to data portability – you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances. You are not required to pay any charge for exercising your rights.
• Your right to withdraw consent – you have the right to withdraw consent provided to us at any time.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of your other data rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other data rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
 

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary
“LAWFUL BASIS”
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

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