dated 18 May 18
to ensure compliance with the
requirements to meet our obligations to all our Subscribers & Users under
The EU General Data Protection Regulation (GDPR)
To help you, we have included some links to other websites. It’s worth remembering though that other people, not us, control these websites we are not responsible for them.
1. About Commuter Barbers
Commuter Barbers is a Website featuring our Barbers Business in York know as Commuter Barbers.
2. Data Controller We are the ‘Data Controller’ of the information you provide us with, which means we control the way information is used and processed.
3. Why we need your information and how we use it
The legal bases we rely on to collect, use, and share personal information is as follows:-
(a) The GDPR requires that we to confirm the legal bases that we rely on to collect, use, and share personal information.
(b) The legal bases include the subscribers affirmative consent to receive marketing messages, compliance with legal obligations, and us the author of the newsletter to use all personal information in their legitimate interests (improving your service, sending you updates, news and promotion discount information and offers).
(c) When you have provided your affirmative consent, which you may revoke at any time, such as by signing up for our mailing list.
(d) If necessary to comply with a legal obligation or court order or in connection with a legal claim, such as retaining information about your purchases if required by tax law; and
as necessary for the purpose of our legitimate interests, if those legitimate interests are not overridden by your rights or interests, such as
(e) providing and improving our services. We use your information to provide the services you requested and in our legitimate interest to improve our services;
5. Information sharing and disclosure
Information about our customers is important to our business. We share your personal information for very limited reasons and in limited circumstances, as follows:
(a) Business transfers. If we sell or merge our business, we may disclose your information as part of that transaction, only to the extent permitted by law.
(b) Compliance with laws. We may collect, use, retain, and share your information if we have a good faith belief that it is reasonably necessary to:
(1) respond to legal process or to government requests;
(2) enforce our agreements, terms and policies;
(3) prevent, investigate, and address fraud and other illegal activity, security, or technical issues; or (4) protect the rights, property, and safety of our customers, or others.
6. Data retention
7. How we collect your personal information?
Subscribing to our service or publications;
(a) request marketing to be sent to you;
(b) give us some feedback;
(c) by filling in forms, for example when you sign up to offers, news or a competition;
(d) by sending us emails and text messages
(e) by adding posts, reviews and other comments to any of our websites social media platforms;
(f) by liking or disliking our offers and promotions;
(g) by interacting with us on social media platforms such as Facebook or Twitter etc;
(h) The usual method at this time is via Subscription form on the Commuter Barbers website, in which we ask for such as your full name, email address, bitwine username, date of birth and Astrological Birth Sign.
8. Automated technologies or interactions.
9. Third parties or publicly available data.
We may receive personal data about you from various third parties as set out below:
10. Technical data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks; and
(c) search information providers.
11. Your personal data
We may collect, store, and use the following categories of personal information about you:
12. Identity data
Title, first name, last name, username, date of birth and gender.
13. Financial data
We do not hold any Bank account or payment card details.
14. Usage data
(a) Information about how you use our website, products and services;
(b) Information on what you view, click on access by way of our marketing emails, website and mobile.
15. Marketing and communications data
Your preferences in receiving marketing from us and your communication preferences.
16. Aggregated data (sometimes referred to a pseudonymised data)
We also collect, use and share Aggregated Data (sometimes referred to a pseudonymised data) such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
17. How we will use information about you?
We will only use your personal information when the law allows us to do so. We will use your personal information in the following circumstances:
(a) When you consent to us to do so;
(b) Where we need to perform the contract we have entered into with you;
(c) Where we need to comply with a legal obligation;
(d) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
(e) Legitimate Interest
means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience;
(f) We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests;
(g)We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law);
(h) We may also use your personal information in the following situations, which are likely to be rare:
Where we need to protect your interests (or someone else’s interests);
Where it is needed in the public interest or for official purposes.
(i) Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us.
If you have expressly opted-in to receive marketing from us we may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant to you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time through our website, clicking the unsubscribe link on any email newsletter we send you, or by contacting us at any time.
You can set your browser to reject all or some browser cookies, or to alert you when websites set or access cookies. If you disable or reject cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies please refer to the cookies section.
20. Change of purpose
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
21. Disclosure & transfer of personal data
On occasion we may have to share your personal data with the parties set out below for the purposes set out. We may store and process your information through third-party hosting services in the EU and other jurisdictions. As a result, we may transfer your personal information to a jurisdiction with different data protection and government surveillance laws than your jurisdiction. If we are deemed to transfer information about you outside of the EU, we rely on Privacy Shield as the legal basis for the transfer, as Google Cloud and WordPress, PayPal and MailChimp are all Privacy Shield certified.
22. Internal third parties
Companies, brands and businesses within our network. Your data will NOT be shared with any corresponding website that we manage or own.
23. External third parties
(a) Service providers: acting as processors based within the EEA who provide IT and system administration services.
(b) Professional advisers: acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the EEA who provide consultancy, banking, legal, insurance and professional service providers.
(c) HM Revenue & Customs, regulators and other authorities: acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
(d) Other people who help us maintain the website.
(e) With social media companies such as Facebook and Twitter: and our advertising partners to enable us to run targeted promotions for you on their platforms;
(f) The Police, local authorities, Her Majesty’s Revenue and Customs (HMRC), the courts and any other government authority: if they ask us to do so (but only if doing so is lawful).
(g) Other people who make a ‘subject access request’: where we are required to do so by law.
We may also share the information we collect where we are legally obliged to do so, e.g. to comply with a court order.
(h) Social media, blogs, reviews, etc.
Any social media posts or comments you send to us: (on the Facebook page, for instance) will be shared under the terms of the relevant social media platform (e.g. Facebook or Twitter) on which they’re written, and could be made public. Other people, not us, control these platforms. We are not responsible for this kind of sharing. Before you make any remarks or observations about anything, you should review the terms and conditions and privacy policies of the social media platforms you use. That way, you’ll understand how they will use your information, what information relating to you they will place in the public domain, and how you can stop them from doing so if you’re unhappy about it. It’s worth remembering too that any blog, review or other posts or comments you make about us and our services on any of our blogs, reviews or user community services will be shared with all other members of that service and the public at large. You should take extra care to ensure that any comments you make on these services, and on social media in general are fit to be read by the public, and are not offensive, insulting or defamatory. Ultimately, you are responsible for ensuring that any comments you make comply with any relevant policy on acceptable use of those services.
24. International transfers
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may securely transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on how we transfer your personal data out of the EEA.
25. Data security
A lot of the information we receive reaches us electronically, originating from your devices, and is then transmitted by your relevant telecoms network provider.
Where it’s within our control, we put measures in place to ensure this ‘in flight’ data is as secure as it possibly can be.
Once it arrives at Commuter Barbers, you can be sure we take the security of your information very seriously.
We use appropriate procedures and technical security measures (including strict encryption, anonymisation and archiving techniques) to safeguard your information across all our computer systems, networks, websites.
We use secure means to communicate with you where appropriate, such as ‘https’ and other security and encryption protocols.
26. How long do we keep your information for?
To make sure we meet our legal data protection and privacy obligations, we only hold on to your information for as long as we actually need it for the purposes we acquired it for in the first place.
In most cases, this means we will keep your information for as long as you continue to subscribe with us and use our services, and for a period of time afterwards if you stop doing so just in case you resubscribe with us again.
After that we will either delete it or anonymise it so that it cannot be linked back to you.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
27. Your rights
If you reside in certain territories, including the EU, you have a number of rights in relation to your personal information. While some of these rights apply generally, certain rights apply only in certain limited cases. We describe these rights below:
You may have the right to access and receive a copy of the personal information we hold about you by contacting us using the contact information below.
29. Change, restrict, delete
You may also have rights to change, restrict our use of, or delete your personal information. Absent exceptional circumstances (like where we are required to store data for legal reasons) we will generally delete your personal information upon request.
You can object to;
(i) our processing of some of your information based on our legitimate interests and;
(ii) receiving marketing messages from us after providing your express consent to receive them. In such cases, we will delete your personal information unless we have compelling and legitimate grounds to continue using that information or if it is needed for legal reasons.
If you reside in the EU and wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local data protection authority.
32. No fee is usually required
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 unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
33. What we may need from you
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.
34. Time limit to respond
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 and keep you updated.
35. Request access
Of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. We may need to verify the accuracy of any new data you provide to us.
36. Request the restriction of processing
Of your personal information. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
37. Request the transfer
Of your personal information to another party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a service for you.
Right to withdraw consent at any time: Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
38. Fees for excessive or unreasonable requests
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
39. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
40. Data Controller – How to contact us
Commuter Barbers (Data Controller) oversees compliance with this privacy notice. If you have any questions or concerns about this Privacy Notice or how we handle your personal information, please contact the Data Controller. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) https://ico.org.uk/, the UK supervisory authority for data protection issues.
Commuter Barbers, George Hudson Street, York, UK
Dated 18 May 18
Version Privacy 1.0