Privacy Policy
Newlyn School of Art – Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals in the European Economic Area (EEA).
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our - Newlyn School of Art Ltd, The Old Board School, Chywoone Hill, Newlyn, Cornwall TR18 5AW
Our data protection officer - Sasha Garfit
Address: Please email us via our 'Contact us' webpage.
Postal Address: Newlyn School of Art, The Old Board School, Chywoone Hill, Newlyn, Cornwall TR18 5AW
Personal data - Any information relating to an identified or identifiable individual
Special category personal data - Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data (when processed to uniquely identify an individual)
Data concerning health, sex life or sexual orientation
Data subject - The individual who the personal data relates to
Personal data we collect about you
The personal data we collect about you depends on the particular products and services we provide to you. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect and use the following personal data about you:
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, your gender (if you choose to give this to us)
- Contact Data includes billing address, delivery address, email address and telephone numbers
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data includes your purchases made/purchase history and/ or orders placed by you and/or on your behalf, including saved items, your interests, preferences, feedback and survey responses including competitions and promotions. Your professional online presence, e.g LinkedIn profile and or information from accounts you link to us, eg Facebook
- Usage Data includes information about how you use our website, IT, communication and other systems, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide the personal data we ask for, it may delay or prevent us from providing products AND/OR services to you.
How your personal data is collected
Direct interactions. We collect most of this personal data directly from you—in person, by telephone, text, correspondence via post or email and/or via our website. This includes personal data you provide when you make a purchase and/or place an order with us via our website, email, telephone or otherwise; request information or marketing to be sent to you; enter a competition, promotion, survey or Application; or give us feedback or contact us. However, we may also collect information:
- from automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect personal data by using cookies on our website. We may also receive technical data about you if you visit our website employing our cookies. Please see our cookie policy included in this document for further details.
- from publicly accessible sources, eg analytics providers such as Google based outside the UK; advertising networks whether based inside or outside the UK; Search information providers whether based inside or outside the UK and identity and contact data publicly available via Companies House and the Electoral Register based inside the UK.
- directly from a third party, eg: sanctions screening providers; credit reference agencies; customer due diligence providers; contact, financial and transaction data from providers of technical, payment and delivery services such as Stripe, Worldpay, GoCardless, DocuSign and Survey Monkey and whether based inside or outside the UK.
- from a third party with your consent, eg your bank or building society
- via our IT systems, eg:
– from door entry systems, reception logs, health and safety medical forms;
– through automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
Cookies and Our Cookie Policy
A Cookie is a small text file stored on your computer and used by your web browser. They can be used for many different purposes, and on this Website some of them are essential to deliver the functionality needed to run this Website and to enrol on a course.
Our Cookie Policy applies to websites operated directly by us.
By accessing this Website, you agree that our Cookie Policy will apply whenever you access this Website on any device. Our Cookie Policy forms part of and is incorporated in our Website Terms and Conditions.
Any alterations and/or amendments to our Cookie Policy will be posted on our website. We reserve the right to vary our Cookie Policy from time to time. Such changes shall become effective immediately after they are posted. Your continued use of the Website constitutes your agreement to all such alterations and/or amendments.
Our use of Cookies
We may collect information automatically when you visit the Website. Such information is stored in a Cookie.
We have placed our use of Cookies into three categories as follows:
Required Cookies;
Analytical Cookies;
Advertising Cookies.
Required Cookies
When you browse our Website, some cookies are required for the site to work correctly. Data is collected via these Cookies for audit purposes. This functionality may include moving around the website, using your account on our site, remembering which course product you have added to the shopping basket, or which payment plan you have selected as your preferred option.
Analytical Cookies
These Cookies monitor how visitors navigate around the Website and how they found it in the first place. We use these Cookies to enable us to monitor total (not individual) figures as to which type of content is most popular with users and also to identify problems with the Website which may need to be rectified or improved upon. This enables us to provide our users with a better experience of using our site.
Advertising Cookies
Our courses are advertised on third-party websites as well as on social networks. We work with third-party media partners to achieve this.
Advertising Cookies store information about the user’s computer. They do not store personal information about the individual. They are likely, however, to store information about which products have been browsed by your computer.
Changing Cookie Settings
You have the option not to use Cookies at all. However, if you choose this option we cannot guarantee that your experience with our Website will be as good as it would have been had you allowed the use of Cookies.
As a final note, information collected by Cookies does not collect information which identifies you personally. It includes general information about your computer settings, your internet connection, IP address, browsing patterns (including timings) and location.
The following links explain how you can control the use of Cookies through your browser:
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
How and why we use your personal data—in more detail
More details about how we use your personal data and why are set out in the table below
How and why we use your personal data—Special category personal data
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:
• personal data revealing racial or ethnic origin, health or gender
Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, eg:
• we have your explicit consent;
• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
• the processing is necessary to establish, exercise or defend legal claims.
How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our products AND/OR services, including exclusive offers, promotions or new products AND/OR services]
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt out of receiving marketing communications at any time by:
• contacting us via our 'Contact Us' webpage;
• using the ‘unsubscribe’ link in our newsletters.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase made or an order placed with us by you.
We may ask you to confirm or update your marketing preferences if you ask us to provide further products AND/OR services in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never sell OR share it with other organisations outside Newlyn School of Art for marketing purposes unless you have opted in to receive marketing from a third-party through a promotion or competition.
Who we share your personal data with
We routinely share personal data with:
• third parties we use to help deliver our products AND/OR services to you, eg payment service providers, warehouses and delivery companies;
• other third parties we use to help us run our business, eg marketing agencies or website hosts;
• third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
• credit reference agencies;
• our bank
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
• our [and their] external auditors, eg in relation to the audit of our [or their] accounts, in which case the recipient of the information will be bound by confidentiality obligations;
• our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
• other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
We will not share your personal data with any other third party.
Who we share your personal data with—further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
Where your personal data is held
Personal data may be held at our offices and third-party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal data with’).
Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see below: ‘Transferring your personal data out of the UK'.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, Emergency Medical information will only be stored for the duration of the course you are attending.
Different retention periods apply for different types of personal data.
If you no longer have an account with us or we are no longer providing goods or services to you, we will delete or anonymise your account data after seven years.
Following the end of the relevant retention period, we will delete or anonymise your personal data.
Transferring your personal data out of the UK
The EEA, UK and other Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases, we will comply with applicable UK laws designed to ensure the privacy of your personal data.
We may transfer your personal data to:
• our service providers located outside the UK
As we are based in the UK we will also transfer your personal data from the EEA to the UK.
Under data protection laws, we can only transfer your personal data to a country outside the UK where:
• in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here. We rely on adequacy regulations for transfers to the following countries:
• in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here. We rely on adequacy decisions for transfers to the following countries:
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or
• a specific exception applies under relevant data protection law.
Where we transfer your personal data outside the UK, we do so on the basis of an adequacy regulation or (where this is not available) issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time, we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR]. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
International transfers of your personal data outside the UK—in more detail
At times we may share your personal data with entities outside the UK. This will involve transferring your data outside of the UK. We have reviewed all our systems and the below are those that process data outside of the UK
Facebook (Ads)/USA/Advertising
Google Ads/Europe/Advertising
Transferring your personal data out of the UK -further information
If you would like further information about data transferred outside the UK, please contact us (see ‘How to contact us’).
Your rights
You have the following rights, which you can exercise free of charge:
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
• email, call or write to us—see : ‘How to contact us’; and
• provide enough information to identify yourself [(eg your full name, address and customer or matter reference number)] and any additional identity information we may reasonably request from you;
• let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorised manner and are subject to a duty of confidentiality.
All account information is password protected. All our website security is regularly reviewed.
We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We endeavour to make purchasing our products and services as safe as we reasonably can. Your browser will automatically default to secure mode before you enter any personal or payment details. To check that you are shopping in a safe environment look for the locked padlock or a key icon in the bar at the bottom of your screen or for the relevant icon in the address bar.
We accept payments using secure third-party platforms Stripe and Worldpay, over the phone or via direct debit service GOCardless. At the Directors discretion we may accept payment by BACS or IBAN. We do not store debit or credit card details on our services once full payment has been processed.
If you want detailed information from, Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Please contact us if you have any queries or concerns about our use of your personal data (see ‘How to contact us’). We hope we will be able to resolve any issues you may have.
The UK’s Information Commissioner may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
This privacy notice was published on 25 April 2023 and last updated on 25 April 2023.
We may change this privacy notice from time to time—when we do we will inform you via our website or other means of contact such as email.
How to contact us
Individuals in the UK
You can contact us and/or our Data Protection Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Our Data Protection Officer's contact details
Newlyn School of Art, The Old Board School, Chywoone Hill, Newlyn, Cornwall TR18 5AW
For emails - Visit our Contact us webpage.
Telephone - 01736 365 557
If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’).