Privacy Policy
for Deer and Sparrow Judith Cupples
Last updated 23 May 2018

Data controller – Judith Cupples, referred to as “we”, “us”, or “our” throughout this privacy notice.

Introduction
This Privacy Policy describes how and when we collect, use, and share information when you purchase an item from us, contact us, take part in a prize draw or competition, or otherwise use our services through Etsy.com, Facebook, Instagram, Paypal, or email (Google), and the related sites and services of these companies.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including Etsy or any third party services you access through Etsy, Facebook, Instagram, Paypal email (Google), Mailchimp, Dropbox and other related services. To learn more about these third-party company’s privacy practices please see their individual websites.

Information we Collect

Personal data is defined as any information capable of identifying an individual. Information is collected in various ways, which are set out below.
o Information collected via direct interaction includes communication by post, email, telephone or otherwise. This includes, but is not limited to, the below interactions:
• Order products or services
• Enter a competition, prize draw, promotion or survey
• Give us Feedback
o Orders placed and/or contact made via Etsy, Instagram, Facebook and Email. To fulfil your order you must provide us with certain information such as:
• Identity: your name, title, email address, marital status, gender.
• Contact: postal address, delivery address, email address, telephone numbers.
• Financial: payment information (bank account and card payment details), and financial transactions. Payments are received via direct bank transfer, Etsy or Paypal.
• Other information – Details of the product you are ordering, and any additional personal information, for example a name for a custom order painting, sign or card, to complete the order.
o Third parties or publicly available sources, such as
• Analytics providers such as Google (based outside the EU).
• Contact information from Mailchimp (based in USA)
• Contact, Financial and Transaction Data services such as Paypal (based in USA)
• Our main shop is on Etsy. Your data is stored by Etsy, (please see their privacy policy for more information).
Sensitive Data
We do not collect any Sensitive Data about you. 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, genetic or biometric data. We do not collect any information about criminal convictions or offences.

By providing us with your data you declare to us that you are over 16 years old.

It is 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 deerandsparrowch@gmail.com.

Where we are required to collect personal data by law, or under the terms of the contract between us and you, and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered. If we do we will notify you at the time.


Why we Need Your Information and How we Use It

We rely on a number of legal bases to collect, use, and share your information, including:
• as needed to provide our services, such as when we use your information to fulfil your order, to settle disputes, to give us feedback or to provide customer support.
• when you have provided your affirmative consent, which you may revoke at any time, such as by signing up for our mailing list.
• 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.
• as necessary for the purpose of our legitimate interests. If those legitimate interests are not overridden by your rights or interests, such as 1) providing and improving our services. We use your information to provide the services you requested and in our legitimate interest to improve our services through feedback, surveys, special offers and other marketing material (you can unsubscribe from marketing emails at any time); and 2) Compliance with the Etsy Seller Policy and Terms of Use. We use your information as necessary to comply with our obligations under the Etsy Seller Policy and Terms of Use.

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:
• Etsy. We share information with Etsy as necessary to provide you with our services and comply with our obligations under both the Etsy Seller Policy and Etsy Terms of Use.
• Service providers. We engage certain trusted third parties to perform functions and provide services to our shop, such as delivery companies, payment service providers, such as Paypal, IT and system administration services, Tax Authorities, Professional advisers (lawyers, bankers etc). We will share your personal information with these third parties, but only to the extent necessary to perform these services.
• 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.
• 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: (a) respond to legal process or to government requests; (b) enforce our agreements, terms and policies; (c) prevent, investigate and address fraud and other illegal activity, security, or technical issues; or (d) protect the rights, property, and safety of our customers or others.

Data Retention
We retain your personal information only for as long as necessary to provide you with our services and as described in our Privacy Policy. However, we may also be required to retain this information to comply with my legal and regulatory obligations, to resolve disputes or to enforce our agreements. We generally keep your data for the following time period: 7 years.

Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We also limit access to your personal data to those employees, agents, contractors and other third parties who have a need to know for this information.

Transfers of Personal Information Outside the EU
As we are based in Switzerland I will be transferring personal information out of the EU. However, I will be abiding by EU GDPR regulations. We may store and process your information through third-party hosting services in the US 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, Mailchimp, Google, DropBox are all Privacy Shield certified.


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:
• Access. 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.
• 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 delete your personal information upon request.
• Object. You can object to (i) our processing of some of your information based on our legitimate interests and (ii) receiving marketing messages from me 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.
• Complain. 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.
• You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, should your request be repetitive, excessive or unfounded we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances. As a security measure, before accessing your personal data we may need to request specific information from you to help confirm your identity. We may also contact you to ask for further information in relation to the request to help speed up our response. We will try to respond to your request within 30 days, occasionally it may take us longer, we will notify you and keep you up to date.

How to Contact Us
For purposes of EU data protection law, I, Judith Cupples (Deer and Sparrow Judith Cupples), am the data controller of your personal information. If you have any questions or concerns you may contact me at judith@deerandsparrow.com.