Terms & Conditions
Your privacy is so important to me…
Cookies
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Privacy Notice
Information Held
I, Gemma Kitto, trading as Born to Birth Cornwall, as a data controller hold certain personal data of individuals who are my clients, potential clients, their birth support partners, their children, business contacts and suppliers. This may include, without limitation, their name, physical address, email address, mobile and/or landline telephone numbers and other information shared with me about their circumstances and plans relating to the services that I provide. I do not hold any sensitive information such as sex, religious beliefs or age.
Basis for Processing
The information I store is solely processed on a lawful basis. In most cases the information is processed on the basis of my legitimate interests on the basis that I have a need to process your information in order to provide my services and operate my business. Personal data may also be processed on other legal basis, including your consent and where I have a contractual obligation to process the data. These uses include, without limitation, providing my services, administration, general record keeping, advertising, marketing, business development and public relations purposes and for the upkeep of my own accounts and invoicing.
Where I process your personal data on the basis of your consent, this consent may be withdrawn at any time on written notice to me.
Collection of Personal Data
The information I process has come from a variety of sources including incoming business enquiries, directly from clients or other business contacts, bookings made via Bookwhen software, bookings made directly through email and telephone communication and through my correspondence and discussions with you in the course of my work.
Protection of Personal Data
I remain constantly vigilant to protect the data I hold. I implement reasonable technical and organisational measures and safeguards to protect your personal data from unauthorised loss, misuse, alteration, or destruction. Despite these efforts, please note that security cannot be absolutely guaranteed against all threats.
Data Retention
I will only keep personal data for as long as I have a valid basis for needing it. I periodically review the data that I hold to make sure that it remains both relevant and up-to-date. Incorrect or out-of-date data will be updated when identified.
Your Rights
You have certain rights in relation to your personal data that I process including the following:
Right to Access: You have the right to access personal data which I hold about you, together with certain information about how and why your personal data is processed.
Right to Rectification: You have a right to request that I correct your personal data where it is inaccurate or out of date.
Right to be Forgotten (Right to Erasure): You have the right under certain circumstances to have your personal data erased. Your information can only be erased if it is no longer necessary for the purpose for which it was collected, and I have no other valid basis for processing the information.
Right to Restrict Processing: You have the right to restrict the processing of your personal data where its accuracy is contested, the processing is unlawful, it is no longer needed for the purposes for which it was collected but I still need it to establish, exercise or defend legal claims or you have exercised the right to object and we have not yet establish if there are of overriding grounds for retention.
Right to Data Portability: In certain circumstances you have the right to data portability, which requires me to provide personal data to you or another controller in a commonly used, machine readable format.
Right to Object to Processing: You have the right to object to the processing of your personal data at any time, but only where that processing is based on my legitimate interests. If you raise an objection, I have an opportunity to demonstrate that I have compelling legitimate interests which override your rights and freedoms.
Where you exercise those rights, I may ask you for additional information to confirm your identity before complying with your request or I may otherwise require additional information from you in order to respond to the request. I reserve the right to charge a fee for complying with a request where I am permitted to do so by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting me. I will make every reasonable effort to comply with your request within the required timeframes but there are circumstances where I may not be able to, or required, to fully comply with your request.
Data Breaches
In the event of a data breach, the risk to you is likely to be low and not likely to affect your rights and freedoms: discrimination, damage to reputation, financial loss, loss of confidentiality or any other significant economic or social disadvantage. However, in the event that exposure to this risk is possible, the ICO will be informed within 72 hours of the breach becoming known, followed by direct correspondence to the individual(s) concerned.
Data Sharing
I do not directly share any of the information that I store with any third party, except as otherwise set out below.
Where I refer you to another related service or contact, I will not share your information with them and will ask that you contact those third parties directly to share your information.
If we agree that I will work with a supporting doula to provide my services, I will be required to share your personal data with the supporting doula to the extent necessary to enable them to assist in providing my services to you.
Where you use a third party booking system to engage my services (such as Bookwhen) please note that they process your personal data as a data processor for me. They only process your personal data to the extent necessary to provide their services to me.
I may from time-to-time run events with third parties where it is necessary to provide a limited amount of your personal data with the third party (such as your name and contact phone number). In this case it will be clear to you that I am working with that third party in order to service the event. Those third parties, in most cases, will process your personal information as a separate and independent controller and you should contact them directly if you wish to exercise any of your rights in relation to the data that they hold.
Contact
If you feels that any aspect of the activities set out above contravenes applicable data protection regulations, please contact me directly and I will endeavour to respond formally within 10 working days. Please be aware that if you believe there is a problem with the way I am handling your data, you also have the right to complain to the ICO (https://ico.org.uk/).
Updates
This policy may be updated from time-to-time. I will notify you of any significant changes but you’re welcome to come back and check it whenever you wish.