Introduction

This privacy notice tells you how we collect and process your personal data when you use our site, from-scratch.net.

From Scratch Communications is the data controller, and we’re responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

By giving us your data, you warrant to us that you are over 13 years of age.
It’s 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 sabine@from-scratch.net.

Contact Details

Until 30 June 2018:

Full name of legal entity: From Scratch Communications Ltd

Email address: sabine@from-scratch.net

Postal address: 2 Cell Farm, Church Road, Old Windsor SL4 2PG

Phone: +44 777 1235024

From 02 July 2018 onwards:

Full name of legal entity: Sabine Harnau, trading as From Scratch  

Email address: sabine@from-scratch.net

Postal address: De Oeverlanden 211, 1441 RE Purmerend, The Netherlands

Phone: +44 777 1235024


What data do we collect about you, for what purpose, and on what grounds do we process it?

Personal data is any info that’s capable of identifying an individual. It doesn’t include anonymised data.

We may process the following categories of personal data about you:

Communication Data

This is any communication that you send to us — whether it’s through:

  • A contact form on our website;
  • Email;
  • Text;
  • Social media messaging;
  • Social media posting; or
  • Messenger owl. 

We process that data in order to communicate with you and for record keeping. While we hope this never happens, we’ll also use it to establish, pursue or defend legal claims. 
It’s in our legitimate interest to process it so we can reply to you, keep the necessary records and deal with legal situations as they occur.

Customer Data

When you buy goods and/or services from us, we process info such as your:

  • Name;
  • Job title;
  • Business info, such as your industry, website, etc.;
  • Billing & delivery addresses;
  • Email address;
  • Phone number; and
  • Purchase details. 

This is to supply the goods and/or services you’ve bought, and to keep records of such transactions. We need to process it so we can perform a contract between you and us — and/or take steps to enter into such a contract (at your request). 

User Data

That’s info about how you use our website and any online services, together with anything you post for publication on our website or through other online services — for example, comments on our blog. 

We process that data to: 

  • run our website and make sure we show you good stuff;
  • make our website secure;
  • maintain back-ups of our website and databases; and
  • enable publication and administration of our website, other online services and business. 

It’s in our legitimate interest to process it so we can properly administer our website and our business

Technical Data

That's data about your use of our website and online services such as: 

  • Your IP address;
  • 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 that data to: 

  • analyse your use of our website and other online services;
  • administer and protect our business and website
  • show you stuff you’ll like on our website; and
  • understand the effectiveness of our advertising.  

It’s in our legitimate interest to process it so we can properly administer our website and our business, grow From Scratch and decide our marketing strategy.

Marketing Data

This includes your preferences in receiving marketing from us, as well as your communication preferences. 

We process this data to: 

  • let you take part in our promotions such as competitions, prize draws and free giveaways;
  • show you good stuff on our website; 
  • make sure that when we advertise, it resonates with you and doesn’t put you off; and
  • measure or understand the effectiveness of that advertising.  

It’s in our legitimate interest to process it so we can study how customers use our products and services, develop our offer, grow our business and decide our marketing strategy.

 

We may use customer data, user data, technical data and marketing data to show you relevant website content and advertisements (including Facebook adverts or other display advertisements) and to understand the effectiveness of the advertising we serve you. It’s in our legitimate interest to process it in this way so we can grow our business. 

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 our business). 

In some cases, we may be legally required to collect your personal data, or it may be necessary under the terms of our contract. In such situations, if you don’t give us that data when we ask for it, we may not be able to perform the contract (for example, to deliver goods or services to you). We may therefore have to cancel a product or service you have ordered. If we do, we’ll let you know at the time.

We’ll only use your personal data for the purpose we collected it for, or for a reasonably compatible purpose if necessary. For more information about this, please email sabine@from-scratch.net

In case we need to use your details for an unrelated new purpose, we’ll let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We don’t carry out automated decision making or any type of automated profiling.

 

Sensitive Data

We don’t collect any sensitive data about you. Neither do we collect any information about criminal convictions and offences.

(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.)


How we collect your personal data

We collect data about you when you give it directly to us (for example by filling in forms on our site or by sending us emails). We may also automatically collect certain data from you as you use our website, by using cookies and similar technologies. Please see our cookie policy for more details about this: from-scratch.net/cookie-policy

We may get data from third parties such as:

  • Analytics providers such as Google based outside the EU;
  • Advertising networks such as Facebook based outside the EU;
  • Search information providers such as Google based outside the EU;
  • Providers of technical, payment and delivery services such as Stripe or Squarespace;
  • Data brokers or aggregators. 

We may also get data from publicly availably sources such as Companies House based inside the EU.


Marketing communications

When we send you marketing communications, it’s either because you’ve given us your consent, or because it’s in our legitimate interest so we can grow our business.

Under the Privacy and Electronic Communications Regulations (PECR), we may send you marketing communications if: 

(i)             you made a purchase or asked for information from us about our goods or services;

or 

(ii)            you agreed to receive marketing communications

and you haven’t opted out of getting such communications since.

Under PECR, if you’re a limited company, we may send you marketing emails without your consent. Of course, you can still opt out of getting them at any time. 

Before we share your personal data with any third party for their own marketing purposes, we will get your express consent.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by emailing us at sabine@from-scratch.net.

If you opt out of getting marketing communications, we’ll still process any personal data you gave us as a result of other transactions (such as purchases, email conversations, etc.). We’ll also still send you emails to confirm any meetings you’ve booked with us, send you proposals you’ve asked for, invoice you as part of our contract, etc.


Sharing your personal data

We may have to share your personal data with the following parties:

  • IT and system administration service providers;
  • Service providers such as Virtual Assistants (VAs) and Marketing consultants who help us with administrative and marketing tasks such as sending out email newsletters, transcribing recorded calls, invoicing, etc.;
  • Professional advisers including lawyers, bankers, accountants and insurers; 
  • Government bodies that require us to report processing activities;
  • Third parties to whom we sell, transfer or merge parts of our business or our assets. 

If you’ve hired us for a project that includes members of the From Scratch network of experts, then we’ll need to share your personal data with them so they can carry out the work set out in our contract. 

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it lawfully. We only allow such third parties to process your personal data for specified purposes and in line with our instructions.


Transferring your data outside the EEA

Countries outside of the European Economic Area (EEA) don’t always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third-party service providers are based outside the EEA. So, we need to transfer your data outside the EEA to use their services and allow them to process it.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data. This means that at least one of the following safeguards must be in place:

  • We’ll only transfer your personal data to countries that the European Commissionhave approved as giving an adequate level of protection for personal data; or
  • We use specific contracts, codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • We use US-based providers that are part of EU-US Privacy Shield, as they have equivalent safeguards in place.

If none of the above safeguards is available, we may ask your explicit consent to the specific transfer. You’ll have the right to say no and to change your mind any time. 


Data security  

We’ve put security measures in place to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. In addition, we allow only those employees and partners access to your personal data who have a business need to know it. They’ll only process your personal data on our instructions and they must 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.


Keeping your data 

We’ll only keep your personal data for as long as we need it for the purposes we collected it — including legal, accounting, or reporting needs.

When deciding how long we should keep it, 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 that information indefinitely without further notice to you.


Your Legal Rights

The data protection laws give you certain rights in relation to your personal data. 

You have the right to request:

  • Access;
  • Correction;
  • Erasure;
  • Restriction; and
  • Transfer of your data.

You also have the right to:

  • Object to processing;
  • Port your data; and
  • Withdraw consent (where the lawful ground of processing is consent).

You can learn more about your rights at: 

ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights

To exercise any of the rights set out above, please email us at sabine@from-scratch.net.

We won’t ask you 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. In those circumstances, we may refuse to comply with your request.

We may need to request specific information from you to help us confirm it’s you and make sure you have the right to access the personal data (or to exercise any of your other rights). This is a security measure so we don’t share that personal data to anyone who has no right to get it. We may also contact you to ask you for more information about 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 that case, we’ll let you know.

If you aren’t happy with any aspect of how we collect and use your data, you have the right to complain.

We’d love to be the first to know if you do have a complaint so that we can try to resolve it for you.

The Information Commissioner’s Office (ICO), is the UK supervisory authority for data protection issues. 

From 15 June 2018, we'll be based in the Netherlands. The Autoriteit Persoonsgegevens is the Dutch supervisory authority for data protection issues. 


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 don’t control those 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.


Cookies

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