Your privacy and the protection of your data is very important to us. We aim to be GDPR compliant. The GDPR law was brought in in 2017 to protects you further from abuse of your data. Since 1997 when we started running courses, we have been highly attentive to protecting your confidentiality and the privacy of your data.
Please excuse the formal and legal nature of this information. We need to provide this information in this way to comply with GDPR law, which is designed to protect you as a user of our website and services. This does not reflect the nature of the Sunflower Effect Courses® – which are friendly and informal and designed to put you at your ease so you can overcome the confidence issues you are facing. We are aiming to make this information as understandable as possible in spite of some of the legal terms.
YOUR CONFIDENTIALITY IS ASSURED
Your confidentiality is assured when participating in any of the Sunflower Effect Courses®, events or sessions. We request confidentiality from all participants so that everyone can feel safe and that whatever they share will not be talked about by other people outside the group.
Very occasionally, we might share a success story in our newsletter. This is with the permission of the participant, in which case they will have the opportunity to remain anonymous if they wish.
This is so the person’s job or public persona won’t be compromised by their employers, clients, friends, family or the public knowing that they participate in this kind of course or because they just don’t want their names bandied around the internet. Many of the reviews have been verified through another organisation who have strict protocols to make sure the review/testimonials are genuine.
Please use the form at the bottom of this page if you want to be in touch with us about anything related to GDPR.
1. WHO WE ARE
This privacy notice provides you with details of how we collect and process your personal data through your use of our site.
Our website address is: https://www.makingmoves.net
By providing us with your data, you warrant to us that you are over 13 years of age. (The minimum age for signing up for our adult courses is 18.)
Claire Schrader is the data controller and is responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our full details are:
Full name of legal entity: Claire Schrader
Email address: claire at sunflowereffect dot com
Postal address: 34 Robin Hood Way, Greenford UB6 7QN
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at claire at sunflowereffect dot com
2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND WHY
Personal data means any information capable of identifying you as an individual. It does not include anonymised data. When we speak about “processing” this means the activity of reading and responding to any information you provide us with in order to support you better through the Sunflower Effect Courses® and sessions.
Communication Data This is any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record-keeping, for advising you on the Sunflower Effect Course® and which will benefit you most. (And in the eventuality of the pursuance or defence of any legal claims.) Our lawful ground for this processing is our legitimate interests which, in this case, are to reply to communications sent to us, to keep records, to support you in your journey through the Sunflower Effect Courses® and to establish, pursue or defend any legal claims. (When we speak about “legitimate Interests” this means that the GDPR law permits us to store and process your data as described.)
Customer Data This is data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your debit/credit card details. We also request when booking one of the Sunflower Effect Courses® or sessions that you inform us of your reasons for attending and any information we need to know to support you better. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us (or in other words delivering the course or session you have booked) and/or taking steps at your request to enter into such a contract.
User Data This is data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and the Sunflower Effect Courses®.
Technical Data This includes data about your use of our website and online services and relates our use of Google Analytics. Google Analytics may track your IP address (to establish your geographical location – this information is not visible to us), details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website, the Sunflower Effect Courses® and to grow the Sunflower Effect Courses® and to decide our marketing strategy.
Marketing Data This includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions and free give-aways, and to deliver relevant website content to you and information about the Sunflower Effect Courses®. Our lawful ground for this processing is our legitimate interests which in this case is to provide you with the information you have requested, to develop the Sunflower Effect Courses® and to make them more available to the people who need them.
We may use Customer Data, User Data, Marketing Data to deliver relevant website content and advertisements (including Facebook adverts) and to measure or understand the effectiveness of our advertising. Our lawful ground for this processing is legitimate interests which is to grow the Sunflower Effect Courses® and make them more available to the people who need them. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow the Sunflower Effect Courses®). [NOTE SEE SECTION 3 BELOW]
We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offences.
We do not carry out automated decision-making or any type of automated profiling.
3. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you our newsletters (marketing communications) is either your consent or our legitimate interests (namely, to grow the Sunflower Effect Courses®).
[Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about the Sunflower Effect Courses® or (ii) you agreed to receive marketing communications, and in each case, you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.]
We do not share your personal data with any third party for their own marketing purposes. It is not in our interests to sell or share your data with third parties for their marketing purposes as trust is an essential part of the Sunflower Effect Courses®. This does not include the Confidence Course Leaders who we have trained in delivering the Sunflower Effect Courses® to you – and who are required to strictly adhere to this privacy notice. In order for them to send marketing information about other services they offer, they must first receive your permission. Please inform us immediately if you are sent unsolicited marketing information from either participants or members of our team as a result of participating in the Sunflower Effect Courses® by emailing claire at sunflowereffect dot com.
You can ask us to stop sending you our newsletters at any time by following the opt-out links on any marketing message sent to you OR by emailing us at claire at sunflowereffect dot com at any time].
If you opt out of receiving our newsletter, this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, registrations etc.
4. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
When you join a course or workshop, you will have the option to be connected up with other participants for the purposes of mutual support and social contact. This is a very important part of participating in our courses, and many groups also set up WhatsApp Groups and keep in touch long after the course has finished. Participants are asked not to use this email group for chain letters, marketing or business purposes without the consent of the individuals in the group. You will have the choice to opt out of this if you wish.
- The Sunflower Effect Course Leaders. We share your data with them only for the purpose of them delivering and supporting you through the Sunflower Effect Courses.
- Service providers (virtual assistants) who provide IT and system administration services. Our virtual assistant has limited access to the data we store about you and is also bound by the code of ethics of their profession. All other service providers that we use to store your data (booking system and newsletter service) are absolutely secure (encrypted and confirm they are GDPR compliant). All are very strict about privacy and spam and have sophisticated ways of blocking any attempts to hack into your information.
- Professional advisers include lawyers, bankers, auditors and insurers.
- Government bodies that require us to report processing activities.
- I am a member of the HCPC (a government body) and the British Association of Dramatherapists in the UK and abide by their code of ethics. I am only required to disclose information that is required legally by them. This has never been necessary to date.
- Third parties to whom we sell, transfer or merge parts of our business or our assets. This currently is not anticipated, but circumstances may arise that demand such measures, in which case we will inform you of our intentions.
We will require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions. You will have the option to opt out of further communication with them.
7. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to our administrative virtual assistant and to our team of Sunflower Effect Course Leaders who need to know such data in order to carry out their administrative duties whilst you are participating in the Sunflower Effect Courses®. They will only process your personal data on our instructions and they are required to keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
8. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances, we may anonymise your personal data for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under data protection laws, you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
If you are within the UK, you can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of the rights set out above, please email us at claire at sunflowereffect dot com.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.
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 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.
We try to respond to all legitimate requests within one month. Occasionally it may 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.
If you are within the UK and are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
If you are within the EU and are not happy with any aspect of how we collect and use your data, you have the right to complain to the data protection authority of the country in which you are based. We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
10. THIRD-PARTY LINKS
This 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 notice of every website you visit.
I am required by law to provide the information described above and take a significant effort to ensure that your data is not breached. Please get in touch if you have any concerns.
My very warmest wishes to you
Please send your GDPR related request to me via this form. I will deal with it as soon as possible and either I or my assistant will be back to you as soon as possible. We recommend you keep a copy of what you’ve written to us in case there is a problem with submission. Please get back to us if you don’t hear from us.