GDPR & Privacy Policy

Personal data I process

1. How I obtain personal data

The information I process about you includes information:

• you have directly provided to me
• that I gather from third party databases and service providers
• as a result of monitoring how you use my website or my services

2. Types of personal data I collect directly

When you use my website, my services or buy from me, [for example, if you create an account on my website,] I ask you to provide personal data. This can be categorised into the following groups:

• personal identifiers, such as your first and last names, your title and your date of birth
• contact information, such as your email address, your telephone number and your postal addresses for billing, delivery and communication
• account information, including your username and password
• payment information, such as a debit or credit card number and expiry date and bank account details
• records of communication between us including messages sent through my website, email messages and telephone conversations
• marketing preferences that tell me what types of marketing you would like to receive

In addition, I may also process:

• documentation that confirms your identity, such as an image of your passport or driver’s licence
• an image that shows your face, such as a passport photograph

3. Types of personal data I collect from third parties

I confirm some of the information you provide to me directly using data from other sources. I also add to the information I hold about you, sometimes to remove the need for you to provide it to me.

The additional information I collect can be categorised as follows:

• information that confirms your identity
• information that confirms your contact information
• unsolicited complaints by other users

4. Types of personal data I collect from your use of my services

By using my website and my services, I process:

• your username and password and other information used to access my website and my services
• information you contribute to my community, including reviews
• your replies to polls and surveys
• technical information about the hardware and the software you use to access my website and use my services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
• usage information, including the frequency you use my services, the pages of my website that you visit, whether you receive messages from me and whether you reply to those messages
• transaction information that includes the details of the products services you have bought from me and payments made to me for those services
• your preferences to receive marketing from me; how you wish to communicate with me; and responses and actions in relation to your use of my services.

5. My use of aggregated information

I may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

For example, I may aggregate usage information to assess whether a feature of my website is useful.

However, if I combine or connect aggregated information with your personal data so that it can identify you in any way, I treat the combined information as personal data, and it will be used in accordance with this privacy notice.

6. Special personal data

Special personal data is data 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.

It also includes information about criminal convictions and offences.

I may collect special personal data about you if there is a lawful basis on which to do so.

7. If you do not provide personal data I need

Where I need to collect personal data by law, or under the terms of a contract I have with you, and you fail to provide that data when requested, I may not be able to perform that contract.

In that case, I may have to stop providing a service to you. If so, I will notify you of this at the time.

The bases on which I process information about you

The law requires me to determine under which of six defined bases I process different categories of your personal data, and to notify you of the basis for each category.

If a basis on which I process your personal data is no longer relevant then I shall immediately stop processing your data.

If the basis changes then if required by law I shall notify you of the change and of any new basis under which I have determined that I can continue to process your information.

8. Information I process because I have a contractual obligation with you

When you create an account on my website, buy a product or service from me, or otherwise agree to my terms and conditions, a contract is formed between you and me.

In order to carry out my obligations under that contract I must process the information you give us. Some of this information may be personal data.

I may use it in order to:

• verify youridentity for security purposes when you use my services
• sell products to you
• provide you with my services
• provide you with suggestions and advice on products, services and how to obtain the most from using my website

I process this information on the basis there is a contract between us, or that you have requested I use the information before I enter into a legal contract.

I shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

9. Information I process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse my website or ask us to provide you more information about my business, including my products and services, you provide your consent to us to process information that may be personal data.

Wherever possible, I aim to obtain your explicit consent to process this information, for example, I ask you to agree to my use of non-essential cookies when you access my website.

If you have given me explicit permission to do so, I may from time to time pass your name and contact information to selected associates whom I consider may provide services or products you would find useful.

I continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us at privacy@mistress-star.co.uk. However, if you do so, you may not be able to use my website or my services further.

I aim to obtain and keep your consent to process your information. However, while I take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent me from continuing to process it. The law may allow me to continue to process your personal data, provided that there is another basis on which I may do so. For example, I may have a legal obligation to do so.

10. Information I process for the purposes of legitimate interests

I may process information on the basis there is a legitimate interest, either to you or to myself, of doing so.

Where I process your information on this basis, I do after having given careful consideration to:

• whether the same objective could be achieved through other means
• whether processing (or not processing) might cause you harm
• whether you would expect us to process your data, and whether you would, in the round, consider it reasonable to do so

For example, I may process your data on this basis for the purposes of:

• improving my services
• record-keeping for the proper and necessary administration of my business
• responding to unsolicited communication from you to which I believe you would expect a response
• preventing fraudulent use of my services
• exercising my legal rights, including to detect and prevent fraud and to protect my intellectual property
• insuring against or obtaining professional advice that is required to manage business risk
• protecting my interests where I believe I have a duty to do so

11. Information I process because I have a legal obligation

Sometimes, I must process your information in order to comply with a statutory obligation.

For example, I may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal data.

12. Information I process to protect vital interests

In situations where processing personal information is necessary to protect someone’s life, where consent is unable to be given and where other lawful bases are not appropriate, I may process personal information on the basis of vital interests.

For example, I may inform relevant organisations if I have a safeguarding concern about a vulnerable person.

How and when I process your personal data

13. Your personal data is not shared

I do not share or disclose to a third party, any information collected through my website.

14. Information you provide

My website allows you to post information with a view to that information being read, copied, downloaded, or used by other people.

For example, when you leave a review or post a message on my website, I reasonably assume that you consent for the message to be seen by others. I may include your username with your message, and your message may contain information that is personal data.

Other examples include:

• tagging an image
• clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks

In posting personal data, it is up to you to satisfy yourself about the privacy level of every person who might use it.

I do not specifically use this information except to allow it to be displayed or shared.

I do store it, and I reserve a right to use it in the future in any way I decide.

I provide you with a public profile page, the information on which may be indexed by search engines or used by third parties. The information you provide on that profile page may be made available to the public.

Once your information enters the public domain, I have no control over what any individual third party may do with it. I accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for us to retain it, then at my discretion I may agree to your request to delete personal data that you have posted. You can make a request by contacting me at privacy@mistress-star.co.uk.

15. Payment information

Payment information is never taken by me or transferred to me either through my website or otherwise. Myself, my employees, or subcontractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of CCBill or some other reputable payment service provider. That page may be branded to look like a page on my website, but it is not controlled by me.

16. Direct Debit information

When you agree to set up a Direct Debit arrangement, the information you give will be used by my payment service provider to process payments to my bank according to my instructions. I do not keep a copy.

17. Information obtained from third parties

Although I do not disclose my personal data to any third party (except as set out in this notice), I sometimes receive data that is indirectly made up from your personal data from third parties whose services I use.

No such information is personally identifiable to you.

18. Third party advertising on my website

Third parties may advertise on my website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on my Website.

They may also use other technology such as cookies or JavaScript to personalise the content of, and to measure the performance of their adverts.

I do not have control over these technologies or the data that these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.

19. Service providers and business partners

I may share my personal data with businesses that provide services to us, or with business partners.

As examples:

• I may pass my payment information to my payment service provider to take payments from you
• I may use fraud prevention agencies and credit reference agencies to verify my identity and I may pass my information to those agencies if I strongly suspect fraud on my website
• I may pass my contact information to advertising agencies to use to promote my services to you

20. Referral partners

This is information given to me by you in your capacity as an affiliate of mine or as a referral partner.

It allows me to recognise visitors that you have referred to me and to credit to you commission due for such referrals. It also includes information that allows me to transfer commission to you.

The information is not used for any other purpose.

I undertake to preserve the confidentiality of the information and of the terms of our relationship.

I expect any affiliate or partner to agree to reciprocate this policy.

Use of information I collect through automated systems

21. Cookies

Cookies are small text files that are placed on your computer’s hard drive by your web browser when you visit a Website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.

They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.

They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements that are relevant to your browsing history.

Some cookies may last for a defined period of time, such as one visit (known as a session), one day or until you close your browser. Others last indefinitely until you delete them.

Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.

The law requires you to give explicit consent for use of any cookies that are not strictly necessary for the operation of a website.

When you first visit my website, I ask you whether you wish me to use cookies. If you choose not to accept them, I shall not use them for your visit except to record that you have not consented to their use for any other purpose.

If you choose not to use cookies or you prevent their use through your browser settings, you may not be able to use all the functionality of my website.

I use cookies in the following ways:

• to track how you use my website
• to record whether you have seen specific messages I display on my website
• to keep you signed in to my website
• to record your answers to surveys and questionnaires on my site while you complete them
• to record the conversation thread during a live chat with my support team

22. Personal identifiers from your browsing activity

Requests by your web browser to my servers for web pages and other content on my website are recorded.

I record information such as your geographical location, your internet service provider and your IP address. I also record information about the software you are using to browse my website, such as the type of computer or device and the screen resolution.

I use this information in aggregate to assess the popularity of the webpages on my website and how I perform in providing content to you.

If combined with other information I know about you from previous visits, the data possibly could be used to identify you personally, even if you are not signed in to my website.

23. Re-marketing

Re-marketing involves placing a ‘tracking technology’ such as a cookie, a ‘web beacon’ (also known as an ‘action tag’ or a ‘single-pixel GIF’) to track which pages you visit and to serve you relevant adverts for my services when you visit some other website.

The benefit of re-marketing technology is that I can provide you with more useful and relevant adverts, and not show you ones repeatedly that you may have already seen.

I may use a third-party advertising service to provide me with re-marketing services from time to time. If you have consented to my use of such tracking technologies, you may see advertisements for my products and services on other websites.

I do not provide your personal data to advertisers or to third-party re-marketing service providers. However, if you are already a member of a website whose affiliated business provides such services, that affiliated business may learn of your preferences in relation to your use of my website.

Other matters

24. Your rights

The law requires us to tell you about your rights and my obligations to you in regard to the processing and control of your personal data.

I do this now, by requesting that you read the information provided at http://www.knowmyprivacyrights.org

25. Use of my services by children

I do not sell products or provide services for purchase by children, nor do I market to children.

If you are under 18, you may not use my website.

26. Encryption of data sent between us

I use Secure Sockets Layer (SSL) certificates to verify my identity to your browser and to encrypt any data you give me.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

27. Delivery of services using third party communication software

With your consent, I may communicate using software provided by a third party such as Facebook (WhatsApp), Apple (Facetime), Microsoft (Skype) or Zoom Video Communications (Zoom).

Such methods of communication should secure your personal data using encryption and other technologies. The providers of such software should comply with all applicable privacy laws, rules, and regulations, including the GDPR.

If you have any concerns about using a particular software for communication, please tell me.

28. Data may be processed outside the UK

My websites are hosted in the United Kingdom.

I may also use outsourced services in countries outside the UK from time to time in other aspects of my business.

Accordingly data obtained within the UK or any other country could be processed outside the UK.

I use the following safeguards with respect to data transferred outside the UK:

• the processor is within the same corporate group as my business or organisation and abides by the same binding corporate rules regarding data processing.
• the data protection clauses in my contracts with data processors include transfer clauses written by or approved by a supervisory authority.
• I comply with a code of conduct approved by a supervisory authority.
• I are certified under an approved certification mechanism as provided for in the Act.
• both my organisation and the processor are public authorities between whom there is either a legally binding agreement or administrative arrangements approved by a supervisory authority relating to protection of your information.

29. Control over your own information

It is important that the personal data I hold about you is accurate and up to date. Please inform me if your personal data changes.

At any time, you may contact me to request that I provide you with the personal data I hold about you.

To obtain a copy of any information that is not provided on my website you should contact me to make that request.

When I receive any request to access, edit or delete personal data I first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Please be aware that I am not obliged by law to provide you with all personal data I hold about you, and that if I do provide you with information, the law allows me to charge for such provision if doing so incurs costs for me. After receiving your request, I will tell you when I expect to provide you with the information, and whether I require any fee for providing it to you.

If you wish me to remove personally identifiable information from my website, you should contact me to make your request.

This may limit the service I can provide to you.

I remind you that I am not obliged by law to delete your personal data or to stop processing it simply because you do not consent to me doing so. While having my consent is an important consideration as to whether to process it, if there is another legitimate basis on which I may process it, I may do so on that basis.

30. Communicating with me

When you contact me, whether by telephone, through my website or by email, I collect the data you have given to me in order to reply with the information you need.

I may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track my communications with you to provide a high quality service.

31. Complaining

If you are not happy with my privacy policy, or if you have any complaint, then you should tell me.

When I receive a complaint, I record the information you have given to me on the basis of consent. I use that information to resolve your complaint.

I aim to investigate all complaints relating to user generated content. However, I may not be able to do so as soon as a complaint is made. If I feel that it is justified or if I believe that the law requires me to do so, I shall remove the content while do so.

Making a complaint may not result in the removal of the content. Ultimately, I have to make a judgment as to whose right will be obstructed: myself, or that of the person who posted the content that offends you.

If I think your complaint is vexatious or without any basis, I shall not correspond with you about it.

If your complaint reasonably requires me to notify some other person, I may decide to give to that other person some of the information contained in your complaint. I do this as infrequently as possible, but it is a matter for my sole discretion whether I do give information, and if I do, what that information is.

I may also compile statistics showing information obtained from this service to assess the level of service I provide, but not in a way that could identify you or any other person.

If a dispute is not settled then I hope you will agree to attempt to resolve it by engaging in good faith with me in a process of mediation or arbitration.

If you are in any way dissatisfied about how I process yourpersonal data, you have a right to lodge a complaint with the Information Commissioner’s Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. I would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

32. Retention period

Except as otherwise mentioned in this privacy notice, I keep your personal data only for as long as required by me:

• to provide you with the services you have requested
• to comply with other law, including for the period demanded by my tax authorities
• to support a claim or defence in court

33. Compliance with the law

My privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).

34. Review of this privacy policy

I shall update this privacy notice from time to time as necessary.