PRIVACY POLICY AND COOKIE POLICY
Last Modified 1 March 2024

A. PRIVACY POLICY

INTRODUCTION
1. WHAT IS A PRIVACY POLICY?
2. WHAT DATA MAY BE COLLECTED, FOR WHAT PURPOSE, AND ON WHAT GROUNDS?
3. HOW AND WHEN IS YOUR PERSONAL DATA COLLECTED?
4. HOW AND WHY MAY WE CONTACT YOU?
5. DISCLOSURES OF YOUR PERSONAL DATA
6. DATA SECURITY
7. DATA RETENTION
8. YOUR LEGAL RIGHTS
9. AGE OF CONSENT
10. SECURITY OF PERSONAL INFORMATION IN YOUR POSSESSION
11. DNT SIGNALS
12. THIRD PARTY LINKS
13. SITE ANALYTICS
14. PRIVACY POLICY MODIFICATION

B.  COOKIE POLICY
15. WHAT ARE COOKIES?
16. BROWSER SETTINGS
17. COOKIE BANNER
18. GENERAL INTERNET SECURITY
19. INFORMATION COMMISSIONER’S OFFICE
20. FURTHER INFORMATION
 
INTRODUCTION
For the purposes of this Privacy Policy and Cookie Policy ‘she’, ‘I’, ‘my’, ‘S W-R’ ‘we’, ‘us’ shall refer to Sara Wallander-Ross. ‘The Site’ shall refer to www.sara-wallander.com. ‘Services’ shall refer to the services rendered to the individual user, in this case singing lessons. ‘Student’ ‘User’, ‘You’ and ‘Yours’ refer to the individual site user.

For the purpose of the Data Protection Act 2018, the data controller is Sara Wallander-Ross. The data processor is Weebly (Squareup International Ltd).

This privacy policy is provided to comply with legal requirements, and to clarify what information is collected and how it is done so. It provides details on how to access your information or to have it deleted all together (‘Right to be Forgotten’), as well as the right to decline or accept cookies. This privacy policy and cookie policy applies to the website www.sara-wallander.com only.
Please read this Policy carefully.  By visiting, browsing, interacting with The Site, and/or sending a lesson enquiry via the contact forms, you are accepting and consenting to the practices described in this policy. You also warrant that you are over 16 years of age. S W-R does not solicit data from children.
 
This Privacy Policy was written in English. If a translated (non-English) version of this Privacy Policy conflicts in any way with its English version, the provisions of the English version shall prevail.
 
1. What is a privacy policy?
A privacy policy is a statement that outlines the ways a website collects, uses, discloses, stores and manages the data of its visitors, browsers and customers. It fulfils a legal requirement to protect a visitor’s or client's privacy.

PRINCIPAL BASES FOR PROCESSING DATA

Consent - Site user has given affirmative consent (opt-in) for their personal data to be processed.

Contract - the processing is necessary for a contract agreed or about to be agreed with the individual user.

Legal or regulatory obligation - the processing is necessary to comply with a law or regulation. Example - collecting information for forwarding to tax or other governmental authorities, or to prevent fraud.

Legitimate interests - the processing is necessary for S W-R’s legitimate interests, or the legitimate interests of a third party. Legitimate interest means the interest she has in managing, conducting and improving her business. Please see Section 2 for more details on what data may be collected and the lawful basis for collecting the different types of data.

2. What data may be collected, for what purpose and on what grounds?
Personal data means any information capable of identifying an individual. It does not include anonymised data.
The following categories of personal data may be collected:
 
a) Customer Data
This may include for instance:
 
  • name;
  • title;
  • email address;
  • address;
  • phone number;
  • other contact details;
  • payment details.
 
We may process this data to supply the services about which you have enquired and to keep records of such enquiries. Our lawful ground for this processing is the performance of a contract between you and us or taking steps at your request to enter into such a contract.
 
b) Communication Data
This includes any communication such as:
 
  • general communications;
  • comments;
  • feedback;
  • reviews; and
  • recommendations
 
that you send to us, whether it be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication path. This data is processed for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. The lawful ground for this processing is legitimate interests, which in this case are to reply to communications sent, to keep records and to establish, pursue or defend legal claims.

c) User Data
This includes data about how you use the website and any online services, together with any data that you post for publication on the website or through other online services. This data is processed to operate the website and ensure relevant content is provided to you, to ensure the security of the website, to maintain back-ups of the website and/or databases and to enable publication and administration of the website, other online services and business. The lawful ground for this processing is legitimate interests, which in this case are to enable proper administration of the website and business.
 
d) Technical Data
This includes data about your use of the website and online services such as:
 
  • Internet protocol (IP) address;
  • login data;
  • browser details;
  • email address;
  • password;
  • computer and connection information;
  • session information, including page response times;
  • length of time spent on certain pages;
  • page interaction information;
  • page views and navigation paths;
  • details about the number of times you use or visit our website;
  • time zone settings and other technology methods used to browse away from the page.

Please see Section 16 for more details on Site Analytics. The lawful ground for such potential processing is legitimate interests, which in this case are to enable proper administration of the website and business, and to further grow the business and decide on marketing strategy, if applicable. Currently no third party Site Analytics is employed on this website but Weebly may collect data as above.

e) Marketing Data
This includes data about your preferences in receiving any potential marketing from S W-R and any third parties as well as your communication preferences, if applicable. The lawful ground for this processing is legitimate interests, which in this case are to study how customers use the services, to develop them, to grow the business and to decide any potential marketing strategy.

S W-R may use Customer Data, User Data, Technical Data and Marketing Data, if applicable, to deliver relevant website content. The lawful ground for this processing is either consent or legitimate interests (namely to grow the business).  

S W-R does NOT collect any sensitive data about you. Sensitive data refers to data which includes details about 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. S W-R does not collect any information about criminal convictions and offences.

Where required to collect personal data by law, or under the terms of the contract between us and you do not provide me with that data when requested, I may not be able to perform the contract (for example, answer enquiries or deliver lessons to you). Should you not provide me with the requested data, I may have to cancel the service you have requested. If I do, I will notify you at that time.

S W-R will only use your personal data for the purpose for which it was collected or a reasonably compatible purpose, if necessary. In the case I need to use your details for an unrelated, new purpose, I will let you know and explain the legal grounds for processing.

S W-R may process your personal data without your knowledge or consent where this is required or permitted by law.

S W-R does not carry out automated decision making or any type of automated profiling.

3. How and when is your personal data collected?  
Your data may be collected by the means of you providing it directly by for example:
  • filling in a form or communicating with S W-R;
  • arranging a lesson by means of using the contact form;
  • visiting and/or browsing the website;
  • engaging with S W-R on social media, if applicable;
  • contacting S W-R for any reason and by any means;
  • choosing to complete any potential surveys sent to you;
  • commenting on, reviewing and/or give feedback about the services.

No relinquishing of personal information is required to use the Site. However, if you choose not to share such information, some parts of the site or facilities within the site may not be accessible or functional. When you provide personal data by any of the above actions or any other actions not included, I deduce that you consent to the collecting and usage of it for the specific reason implied only. This is not an exhaustive list.

4. How and why may S W-R contact you?
S W-R may contact you for the managing of provision of the services, and/or to pursue her legitimate interest, or as otherwise necessary to enforce her Terms and Conditions, applicable national laws, and any agreement she may have with you. For these purposes she may contact you via email, telephone, text messages, and postal mail.

5. Disclosures of your Personal Data
S W-R may have to share your personal data with parties such as those set out below in order to fulfil any contracts or undertakings agreed between us, to provide any Services agreed or to comply with applicable Law:
  • Service providers who provide IT and system administration services, including Weebly
  • Professional advisers, including lawyers, bankers, auditors and insurers
  • Government bodies that require her to report processing activities
  • Banks or payment agencies
  • Third parties to whom she sells, transfers, or merges parts of her business or her assets
    ​
All potential third parties to whom S W-R may transfer your data are required to respect the security of your personal data and to treat it in accordance with the law. S W-R only allows such third parties to process your personal data for specified purposes and in accordance with her instructions, to the best of her ability.

Third-party service providers have separate privacy policies. It is recommended that you read any relevant privacy policies so you understand the manner in which your personal information will be handled.

In particular, be mindful that certain providers may be located in, or possess facilities located in other jurisdiction(s) from yours or mine. If you chose to proceed with an action that involves the services of a third-party service provider, your information may become subject to the laws and regulations of the geographical jurisdiction(s) in which the relevant service provider or connected facilities are situated.

S W-R will never sell your information to third party organisations.

6. Data Security
There are security measures, including SSL secure access to the Site, to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. Whilst S W-R makes every effort to safeguard your data, please remember that no Internet transmission method, nor any digital or physical storage is completely secure, and its absolute security cannot be guaranteed.

S W-R will notify you and any applicable regulator of a breach if legally required to.

This website is hosted on the Weebly.com platform. Your data may be stored through Weebly.com’s data storage, databases and the general Weebly.com applications.

7. Data Retention
S W-R will only retain your personal data for as long as necessary to fulfil the purposes for which it has been collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding the correct time period for which to keep the data, S W-R looks at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes and if these can be achieved by other means, as well as legal requirements.

For tax purposes, the law requires S W-R to keep basic information about Users/Students (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances your personal data may be anonymised for research or statistical purposes, in which case S W-R may use this information indefinitely without further notice to you.

8. Your Legal Rights
How can you access your data, opt out or ask for your data to be deleted?
You have the right to access, correct, amend, restrict, transfer, object to processing or portability of data and delete any personal information S W-R possesses about you, as well as where the lawful ground of processing is consent, to withdraw consent. If you wish to exercise this right, or if you want us to cease processing your data, please contact S W-R at [email protected]. Please head any communication ‘Data Processing’. Such requests will be dealt with promptly, at least within 30 days, as long as the request does not concern or contravene the prevention, detection or investigation of a crime, national security or the armed forces, the assessment or collection of tax, judicial or ministerial appointments or there is not deemed to be an overriding legitimate interest in the denial of such a request or the request is unlawful or unreasonable. Occasionally it may take longer than 30 days if your request is particularly complex or you have made a number of requests. In this case, you will be notified.
There is no fee for such requests, unless the request concerns a large amount of information, is deemed to take a long time and much effort to process or is clearly unfounded, repetitive or excessive. In such a case, a reasonable fee may be charged or S W-R may refuse to comply with your request.
S W-R may need to request specific information from you to help 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. S W-R may also contact you to ask you for further information in relation to your request to speed up the response.

Your personal information may be disclosed to governmental and/or legal institutions if S W-R is under legal obligation to do so or if you violate the Terms and Conditions.

If you are within the UK, you can see more about these rights at:
ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

9. Age of consent
By using this site, you represent that you are at least 16 years of age.  S W-R does not knowingly collect or solicit data from or market to children or teenagers under 16 years of age. If I become aware that personal information from minors has been unknowingly collected, I will take reasonable measures to delete such data from my records.

10. Security of your personal information whilst in your possession
Please note that S W-R accepts no liability for any damage or loss that is incurred by your personal credentials having been knowingly or unknowingly shared, lost or accessed by other persons due to carelessness on your part, and in absence of negligence on S W-R’s part. If you share a computer or use a public computer, you are advised to enquire regarding the safety of any public wi-fi network, not to use Hot-Spots, not to charge your device with a publicly available charger, such as in an airport, never to leave your device open and unattended and remain vigilant at all times.

11. DNT signals
Please note that the processor platform Weebly does not change their practices in response to a “Do Not Track” signal in the HTTPS header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser. Please inform yourself regarding what permissions and settings are available to you on your browser. Please see section 16 regarding links to the most common browsers.

12. Third Party Links
This site may contain links to other websites or services, including third party applications. S W-R is not responsible for the privacy policies of such websites, services or companies, nor their handling of your data. Any time you click on a link to another site or application, please be aware that you are leaving sara-wallander.com. Do inform yourself of the privacy practices of all websites and services you peruse before considering providing personal information. This Privacy Policy and the Terms and Conditions do not apply to such linked third party websites and services and by leaving this Site you are no longer governed by this Privacy Policy or Terms and Conditions. S W-R takes no responsibility for neither the full content, nor the practices, practical, ethical or moral of such third party websites or services, and excludes all liability that may arise in connection with or as a result of encountering such external website material (imagery or written content); any malicious component or code; cookies; as well as any damage incurred (mental, physical, punitive or material), costs (direct or indirect), injury or loss (financial, mental, personal, material or of any kind).

13. Site analytics
S W-R does not use third party analytics, however Weebly may record user analytics.

14. Privacy Policy Modification
S W-R reserves the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If material changes are made to this policy, I will notify you here on this Privacy Policy page that it has been updated, so that you are continuously aware of what information collected, how it is used, and under what circumstances, if any, it is used and/or disclosed. It is each individual User’s responsibility to keep themselves up to date with the current Privacy Policy.

B.COOKIE POLICY
 
15. What are Cookies?
Cookies are essential to the effective running of most websites. They are used as a means of communication between websites and servers and are created when a user's browser loads a website. A ‘cookie’ contains information which is stored on your computer’s hard drive (if you agree to this), which triggers the browser to create a text file. It records how you move around the site so that, every time you return to that same website, the browser retrieves and sends the text file to the website's server. This way it can present tailored options based on the information stored about your last visit.

Cookies can also be used to analyse traffic and for advertising and marketing purposes. Cookies are used by almost all websites and do not harm your system.

In general, cookies are used to:

  • authenticate a user using a secure area of a website, such as a user account;
  • store information regarding a user’s activities;
  • store information regarding shopping carts;
  • facilitate ads.

This is not an exhaustive list of the general use of cookies. To read more about cookies, please visit www.allaboutcookies.org

S W-R is required to obtain your consent for all non-essential cookies used on the website. You can block cookies at any time by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block essential cookies you may not be able to access all or parts of the site.

TYPES OF COOKIES
Cookies are either:

  • session cookies: these are only stored on your computer during your web session and are automatically deleted when you close your browser – they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any personal data from your computer;
 
         OR
 
  • persistent cookies: a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you revisit said website.

Cookies can also be categorised as follows:

Essential cookies (Strictly necessary Cookies)
Essential cookies make it possible to navigate the Site and use its features. They cannot be turned off. These cookies are essential to enable you to use the website effectively, such as when buying a product and/or service. Without these cookies, the services available to you on the website cannot be provided. These cookies do not gather information about you that could be used for marketing, nor do they remember where you have been on the internet.

Functional cookies
These non-essential cookies allow the Site to remember User choices or preferences. They allow a website to remember choices you make and provide enhanced features. They may also be used to provide services you have requested such as viewing a video, commenting on a blog or using the chat function. The information these cookies collect is usually anonymised. 
​Vimeo is integrated on the site, but the videos have DNT parameter enabled and do not set any cookies, apart from essential cookies needed for the functionality of the video player. 

Performance and Analytical Cookies
Also a non-essential cookie, these gather information about how visitors like yourself use the site. These cookies enable monitoring and improving the performance of a website. For example, they count visits, identify traffic sources and see which parts of the site are most popular. These cookies don’t collect personally identifiable information.  S W-R does not use third party site analytics but Weebly may record page visits, identify traffic sources etc. Again, this data contains no personally identifiable data.

Targeting and Advertising cookies
These cookies record your visit to a website, the pages you have visited and the links you have followed. 

Social Media Cookies
There are no social media linked to this site.

16. Browser settings
The following links explain how to access and change cookie settings in various browsers:
   
17. Cookie Banner
 When you enter the Site, you will see a cookie banner pop up. This gives you the option to either accept all cookies, decide which cookies to accept or decline all non-essential cookies. You can always change your cookie settings by going to Cookie Preferences in the bottom left corner.
 
18. General Internet Security
It is recommend that you always keep up to date with security and software updates, both on your computer, phone and/or tablet. Use a reputable anti-virus programme and set your browser’s cookie policy to a level with which you personally are comfortable. Please take care when browsing and interacting with Sites on the internet.
 
19. Information Commissioner’s Office
Should you have any complaints, please contact the Information Commissioner’s Office. I would however politely ask that you contact me first, to enable me to address your concerns.

ICO
Telephone: 0303 123 1113
Textphone: 01625 545860
Monday to Friday, 9am to 4:30pm
Information Commissioner’s Office
Wycliffe House Water Lane
Wilmslow
Cheshire
SK9 5AF