Privacy and Cookie Policy

1. What is the legal basis for collecting personal data?

Data Protection legislation gives various reasons why a company could collect and process your personal data. I use the ICO lawful basis interactive guidance tool where necessary to determine legal basis and am the data controller as a sole trader, Christina Poulton.

The legal basis that apply to my work are:

Consent

Christina Poulton can collect and process your data with your permission. An example of this is when you choose to sign up for my mailing list. Sometimes you might give your consent implicitly, such as when you send me an email to which you would reasonably expect me to reply.

Contractual obligations
Christina Poulton may need your personal data to comply with contractual obligations. For example, if you purchase a ticket from me for some training, I would use your details to provide access to the training.

Legal obligation
Christina Poulton may be required to disclose your personal data by a court order or to comply with other legal requirements. I aim to inform you of this requirement wherever possible, unless I am legally restricted from doing so. For example, I can pass on details of people involved in criminal activity to the police.

Legitimate interest
In specific situations, I require your data to pursue our Legitimate Interests in a way which might reasonably be expected as part of running our business or acting in your best interests and which does not materially impact your rights, freedom or interests. For example, I may use your details from a previous enquiry about some training or to work with me, to send you details of other similar work I am doing that I think you may be interested in.

2. What types of personal data do I collect and how do I use it?

Please note I have tried to be as detailed and comprehensive about what data I collect and how it is used, but the below is indicative. Any data collection or usage will be closely comparable to the examples below. Any significant changes or additions that would not be reasonably expected will be dealt with through updates to the policy (see section 6 below).

Participants on training or workshops

What do I collect? Contact details and information about your area of work or what you want to learn

How do I use it? I collect contact details so I can provide the information you need to access the training and get the most out of it e.g. sending the zoom link or sharing slides and resources used in the training. I collect information about your area of work etc usually through custom questions in a sign up form for the training. These are optional where possible and if you choose to provide the information I use it to plan the training to make it as useful as possible e.g. to make sure examples given are relevant.

Q&A Community (online community provided with some training courses)

What do I collect? The log in details you use for the community (e.g. user name. Any log in password etc would be encrypted by the platform used to provide the community). Any information you choose to share in the questions or replies you post.

How do I use it? To reply to your questions. I may use the information you provide to identify general trends in topics that may be worth creating a specific training offer for, but this will be aggregated and anonymised data, not personally identifiable.

Feedback

What do I collect? Feedback on training sessions or work I have competed with you, that you submit via email, Zoom chat or social media.

How do I use it? To monitor the effectiveness of my work. I sometimes use quotes to help promote future training, shared via the sign up page for that training, my website or social media. If I do this it will always be with your specific permission which you can choose to withhold.

Mailing list

What do I collect? I will collect your name and email address

How do I use it? I will send you my newsletter, which includes resources and tips as well as information about new training or opportunities I offer.

I may also use this information to carry out targeted advertising on social media, for example using Meta lookalike and custom audiences and Google lookalike audiences.

Your data will be ‘hashed’ by both me and the platform before this is carried out which means it is pseudonymised. In addition if you have opted out of this in your own Facebook profile, for example, then Meta won’t be able to use your data in this way.

I do this to help advertising for new opportunities to be relevant and useful both to me and current and potential audiences and avoid unnecessary repetition.

Website

What do I collect? Your name and email address via my contact form if you choose to submit a contact request. As well as essential cookies to make the website work properly, I may use some preference, statistics and advertising cookies and tracking pixels.

How do I use it? To reply to your request via the contact form by email, and to let you know about other opportunities that I feel are relevant to you based on your contact. For use of cookies and pixels, please see information on cookies below.

Third Party Data Processors

Christina Poulton holds your details securely using tools that I have audited to ensure they meet my security standards. If you want to change the way in which I communicate with you or stop communications from me you can do so at any time by clicking the unsubscribe link on my mailing list emails or emailing hello@christinapoultoncreative.co.uk

Gsuite (gmail, Google docs, Gdrive etc): I use Google tools to store business information which may include personal data. For example, creating invoices with your name and address on if I am invoicing you for work completed. You can see Google’s Privacy Policy here policies.google.com/privacy

Funnelsketchers: I use Funnelsketchers to store email address and names in order to send emails to my mailing list and to track interactions from those newsletters. I also use it to host my online training and Q&A community. You can see Funnelsketchers’s Privacy Policy here https://funnelsketchers.com/privacy-policy/

Wix: I use Wix to host my website, which includes my contact form. You can view Wix’s Privacy Policy here. https://www.wix.com/about/privacy

Zoom: I hold meetings and events in zoom and use the chat files to collect feedback. The Zoom privacy policy is here: https://explore.zoom.us/en/gdpr/

Fathom: I use Fathom to transcribe virtual meetings so I can have a record of what was said. The conversations are always private, only accessible to those in the meeting. I will let you know at the start of a meeting if I plan to use this and you can choose if you don’t wish to proceed. You can read the Fathom privacy policy here. https://fathom.video/privacy

Miro: I use Miro as a collaborative tool in workshops. I do not collect any information intentionally here but if you chose to include personal data in anything you typed this would remain on the Miro board and only be used for its original purpose. Miro’s privacy policy is here https://miro.com/legal/privacy-policy/

Financial information: Financial information is processed by one of two providers. I use Paypal for payment for services. You can see their Privacy Policy here https://www.paypal.com/myaccount/privacy/privacyhub/principles. I also use Stripe for payment for services. You can see their Privacy Policy here https://stripe.com/gb/privacy

3. External Links

christinapoultoncreative.co.uk contains links to other websites. When you click on any of these links you are moving onto another site and their terms, conditions and policies will apply when you are visiting their pages. These terms and conditions may differ from those of Christina Poulton.

4. Sharing data with third parties

Christina Poulton does not sell, rent or distribute any personally identifying data from our users to third parties for commercial purposes without your prior consent. The only time I share data is with third party data processors for the purposes, and in the ways outlined above. I remain the data controller in these instances.

5. Data retention and deletion

Any personal data that I process for any purpose shall not be kept for longer than is necessary for that purpose. You may instruct me to provide you with any personal data I hold about you (known as a Subject Access Request). This may be subject to the supply of appropriate evidence of your identity.

There’s more information about how you can do this, timelines and possible costs here: https://ico.org.uk/for-the-public/getting-copies-of-your-information-subject-access-request/

6. Cookies

I use cookies on my website www.christinapoultoncreative.co.uk

Cookies are small pieces of computer code which help websites run better and can also serve other functions. More info about cookies- what they are and how they work- can be found here: https://allaboutcookies.org/

I use essential cookies to make my site work.

With your consent, I may also use non-essential cookies or similar things, like pixels, to improve your experience of using my website, analyse or track website traffic or for advertising. Some online tracking technologies help maintain the security of the website and your interactions e.g. making payments, or prevent crashes, fix bugs or save your preferences.

The list of cookies my website uses is here.

When you visit my website you can choose to accept all cookies or select your preferences. However, without some of these cookies, certain functionality (like videos) may become unavailable.

The following links explain how to access cookie settings in various browsers:

Google Analytics

If you accept the relevant cookies I may share your information with Google Analytics to track and analyse the use of our website and use their advertising feature, Google Ads. To opt out of being tracked by Google Analytics you can also visit https://tools.google.com/dlpage/gaoptout

The types of cookies that may be used on my website are below

Essential Cookies

These cookies are necessary to the core functionality of my website and some of its features, such as access to secure areas.

Performance and Functionality Cookies

These cookies are used to enhance the performance and functionality of the websites but are nonessential to their use. However, without these cookies, certain functionality (like videos) may become unavailable.

Analytics and Customisation Cookies

These cookies collect information that can help me understand how my website is being used. This information can also be used to measure effectiveness in my marketing or to curate a personalised site experience for you.

Advertising Cookies

These cookies are used to make advertising messages more relevant to you. They prevent the same ad from continuously reappearing, ensure that ads are properly displayed for advertisers, and in some cases select advertisements that are based on your interests.

Social Networking Cookies

These cookies enable you to share the website's content through third-party social networks and other websites. These cookies may also be used for advertising purposes.

Unclassified Cookies

These are cookies that have not yet been categorised. We are in the process of classifying these cookies with the help of their providers.

7. Updating this Privacy Policy

I may update this statement by publishing a new version on my website. You should check this page occasionally to ensure you are happy with any changes to this policy. If there are significant differences to how I plan to use personal data collected in the course of my work I will inform you via email.

If you have any questions about the Policy or would like to update your details please contact me via my website.