Privacy Policy

Lucky Girl Academy understands that your privacy is important to you and that you care about how your Personal Data is used and shared online. We respect and value the privacy of everyone who visits this website, https://clairespencer.co.uk/ (“Our Site”) and will only collect and use Personal Data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy & Cookies Policy carefully and ensure that you understand it. It explains how We handle your Personal Data.

1.       Definition and Interpretation

In this Policy the following terms shall have the following meanings: 

2.       Information About Us

         Our Site https://clairespencer.co.uk/ is owned and/or operated by Us.

3.       What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4.       Your Rights

a.       As a data subject, you have the following rights under the Data Protection Legislation, which this Policy and Our use of Personal Data have been designed to uphold:

i.        The right to be informed about Our collection and use of Personal Data;

ii.       The right of access to the Personal Data We hold about you (see section 12);

iii.      The right to rectification if any Personal Data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);

iv.      The right to be forgotten – i.e., the right to ask Us to delete any Personal Data We hold about you (We only hold your Personal Data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);

v.       The right to restrict (i.e., prevent) the processing of your Personal Data;

vi.      The right to data portability (obtaining a copy of your Personal Data to re-use with another service or organisation);

vii.     The right to object to Us using your Personal Data for particular purposes; and

viii.     Rights with respect to automated decision making and profiling.

b.       If you have any cause for complaint about Our use of your Personal Data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.

c.       For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5.       What Data Do We Collect?

Depending upon your use of Our Site, We may collect some or all of the following personal and non-Personal Data (please also see section 14 on Our use of Cookies and similar technologies):

a.       Name;

b.       Email; and

c.       Address.

6.       How Do We Use Your Data?

a.       All Personal Data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under theData Protection Legislationat all times. For more details on security see section 7, below.

b.       Our use of your Personal Data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your Personal Data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

i.        Personalising and tailoring your experience on Our Site;

ii.       Supplying Our products and services to you (please note that We require your Personal Data in order to enter into a contract with you);

iii.      Personalising and tailoring Our products and services for you;

iv.      Replying to emails from you;

v.       Market research;

vi.      Analysing your use of Our Site to enable Us to continually improve Our Site and your user experience; and

vii.     Where you have separately consented for marketing purposes.

c.       You have the right to withdraw your consent to Us using your Personal Data at any time, and to request that We delete it.

d.       We do not keep your Personal Data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):

i.        We will retain your contact details for as long as we contract with you and for 24 months thereafter, with exception of financial information as detailed in iv. below;

ii.       We will retain your contact details for 24 months if you have enquired about our services thereafter, they will be deleted;

iii.      If you sign up to Our mailing list, We will retain your personal data for as long as you consent to receive emails from us. You can unsubscribe at any time and We will remove you from Our mailing list and thereafter We will delete your details.

iv.      will retain your financial information for as long as we contract with you and, thereafter, for the permitted period of time required by law. We will retain your financial information, which could include your name, address and email address, for as long as we contract with you and, thereafter, for the permitted period of time required by law.

7.       How and Where Do We Store Your Data?

a.      We only keep your Personal Data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

b.      We will store some of your Personal Data in the UK. This means that it will be fully protected under the UK’s Data Protection Legislation.

c.      We will store some of your Personal Data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your Personal Data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of Personal Data to the EEA from the UK are permitted without additional safeguards.

d.      We may store some or all of your Personal Data in countries outside of the UK and EEA. These are known as “third countries”. We will take additional steps in order to ensure that your Personal Data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.

e.      We use the following third-party software and some of your data may be stored on their servers:

i.        FluentCRM;

ii.       Elasticmail;

iii.      Stripe; and

v.       Surecart.

f.        Steps We take to secure and protect your data include:

i.        All devices and computers that we store your data on are password protected;

ii.       All devices and computers that we store your data have anti-virus software and are constantly updated to the most recent operating system; and

iii.      We only store your data on computers and devices owned by Us. We also use Contractors who may store Our data on their computers, servers and any such cloud storage they may access. We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

8.       Do We Share Your Data?

a.       We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.

b.       We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.

c.       We may sometimes use third party data processors that are located outside of the United Kingdom and European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any Personal Data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK under the Data Protection Legislation including:

i.        Using Standard Contractual Clauses “SCCs” as a mechanism to safely process data outside of the UK and EEA to third countries which have not been granted adequacy; or

ii.       Is a Country that has been granted adequacy which confirms its data protection legislation is adequate to safeguard data processing.

d.       In certain circumstances, We may be legally required to share certain data held by Us, which may include your Personal Data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.

e.       Some parts of Our Site allow visitors to leave comments, such as Our blog page. If you do leave a comment and disclose your personal data within that comment, please be aware that any other visitors are able to see that information. You therefore do this at your own risk and we have no control of the personal data in that instance.

9.       What Happens If Our Business Changes Hands?

a.       We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any Personal Data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy & Cookies Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

b.       In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

10.     How Can You Control Your Data?

In addition to your rights under the Data Protection Legislation, set out in section 4, when you submit Personal Data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our site of your data for direct marketing purposes (including the ability to opt-out if receiving emails from Us which you may do by subscribing using the links provided in Our emails and at the point of providing your details.

11.     Your Right to Withhold Information

a.       You may access Our Site without providing any data at all.

b.       You may restrict Our use of Cookies. For more information, see section 13.

12.     How Can You Access Your Data?

You have the right to ask for a copy of any of your Personal Data held by Us (where such data is held). Under the Data Protection Legislation, no fee is payable and We will provide any and all information in response to your reasonable request free of charge. Please contact Us for more details at section 14 or use the contact details below in section 14.

COOKIES POLICY

13.     Our Use Of Cookies

14.     Contacting Us

If you have any questions about Our Site or this Privacy Policy, please contact Us by email at claire@clairespencer.co.uk Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).

15.     Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site. This policy was last updated on 13^th March 2024.