Privacy Policy

1.       Introduction
1.1    We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.
1.2    By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

2.       Credit
2.1    This document was created using a template from SEQ Legal (http://www.seqlegal.com).

3.       How we use your personal data
3.1    We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.

3.2    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent.

3.3    We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.  The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

3.4    We may process any of your personal data identified in the other provisions of this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

3.5    In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.6    Please do not supply any other person's personal data to us, unless we prompt you to do so.

4.       Providing your personal data to others
4.1    We may disclose your personal data to professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice and managing legal disputes.

4.2    Your personal data is accessible to our authorized staff at our software developer the Solutions Factory insofar as reasonably necessary for the purposes of maintaining our database and website.

4.3    Financial transactions relating to our website and services are handled by our payment services provider, PayPal (https://www.paypal.com). We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://www.paypal.com/uk/webapps/mpp/ua/legalhub-full.

4.4    If you sign up for our newsletter, which is administered through Mailchimp, or if you register for our site, we will store some of your information, including your email address, IP address and certain information about the links you click within the emails we send you, on a Mailchimp server. Neither we nor Mailchimp will ever sell your email address or share it with any other party, unless we are legally compelled to do so. If you contact Mailchimp directly regarding your subscription to our newsletter, Mailchimp may contact you directly; otherwise, Mailchimp will never contact you. Only authorized Mailchimp employees have access to our subscriber list. You are always free to unsubscribe from our newsletter, but as long as you are registered with this is somatic we may use Mailchimp to send you information about your account.  You can find information about MailChimp’s privacy policy at https://mailchimp.com/legal/privacy/.

4.5    In addition to the specific disclosures of personal data set out in this Section 4, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

5.      Retaining and deleting personal data
5.1    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.2    We will retain the minimum amount of personal data for the purpose of our booking system and accounting system. We will review the data and period of retention annually.
5.3    We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

6.       Amendments
6.1    We may update this policy from time to time by publishing a new version on our website.

6.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

7.      Your rights
7.1    We have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

7.2    Your principal rights under data protection law are:
(a)    the right to access;
(b)    the right to rectification;
(c)    the right to erasure;
(d)    the right to restrict processing;
(e)    the right to object to processing;
(f)    the right to data portability;
(g)    the right to complain to a supervisory authority; and
(h)    the right to withdraw consent.

7.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge.

7.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

7.5    In some circumstances you have the right to the erasure of your personal data without undue delay. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary for the establishment, exercise or defence of legal claims.

7.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

7.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

7.8    You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.

7.10  To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.11  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

7.12  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

7.13  You may exercise any of your rights in relation to your personal data by written notice to us.

8.      About cookies
8.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

8.2    Cookies will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date.

8.3    Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

9.      Cookies that we use
9.1    We use cookies to identify you when you visit our website and as you navigate our website and to store information about your preferences and to personalise the website for you and we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally.

10.    Managing cookies
10.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e)    https://support.apple.com/kb/PH21411 (Safari); and
(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

10.2  Blocking all cookies will have a negative impact upon the usability of many websites.  If you block cookies, you will not be able to use all the features on our website.

11.    Our details
This website is owned and operated by
Andrea Paget and Eeva-Maria Mutka t/a Penpynfarch
Our principal place of business is at Penpynfarch, Llandysul, Carmarthenshire, SA44 4RU. 
You can write to use at this address or call us on 01559 389 917 or email us at enquiries@penpynfarch.co.uk.