Six String Fingerpicking - Privacy Notice
1. Who are we?
Six String Fingerpicking aims to provide you with the highest quality service whilst you are accessing our services. To do this, we must keep records about you and the services we provide for you. We aim to maintain high standards, adopt best practice for our record keeping and regularly check on how we are doing.
Being transparent and providing accessible information to individuals about how we will use their personal data is a key element of the Data Protection Act 1998 (DPA) and the EU General Data Protection Regulation ("GDPR").
2. What are Six String Fingerpicking's obligations under GDPR as a Data Controller?
Six String Fingerpicking is the Data Controller because it determines why your data is being processed and how it is being processed.
Personal data means any information capable of identifying a living individual. It does not include anonymised data.
Processing is anything that is done with personal data including collecting, recording, structuring, storing, adapting, altering, retrieving, consulting, use and disclosure.
We will handle your information correctly and protect your privacy. Relevant information will only be shared with trusted organisations contracted to process data on behalf of Six String Fingerpicking or where required to by law and with sound legal basis (see sections 6 and 7).
3. How and why are we processing your personal data?
We may collect and process your personal data in a different ways:
Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting, commenting on the website or any other communication that you send us.
We use Communication Data to help tailor our services and provide more content that takes into account your feedback. We also use it to answer your queries and provide personal responses. Communication Data is not used for marketing purposes and you will only be added to the Mailing List if you explicitly request it.
Marketing Data that includes data about your preferences in receiving marketing from us and your communication preferences. This is provided by subscribing to the Six String Fingerpicking Mailing List.
We use Marketing Data to deliver relevant email content to you and to measure or understand the effectiveness of the content we provide you. The personal data you have provided is your email address, and in some instances also your name. This is so that you can receive email notification of new content published to www.sixstringfingerpicking.com as well as new offers, sales, and courses available to purchase. The personal details provided will be used only for this purpose.
Technical Data that includes data about your use of our website and online services, which may include your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from the WordPress analytics system, Sumo and Google Analytics.
We use Technical Data to allow users to log in to the website and close inactive sessions. It may also be used to reduce errors and improve the the user experience.
Some cookies are used for other purposes, such as recording what your preferred settings are so they can be loaded when you revisit a website, for example this could include remembering what items are in your shopping cart. Cookies are used to improve your overall browsing experience. They can also be used to analyse traffic for advertising and marketing purposes.
Session cookies last only whilst your browser is open and will be automatically deleted when you close your browser. Persistent cookies last until they expire or until you delete them.
If you don't wish to allow cookies you can adjust your browser settings. Some browsers will allow you to manage settings for individual websites so that you can disallow cookies from all sites except those on your trusted list.
5. Under what legal basis do we collect and process your data?
We rely on consent as the lawful basis on which we collect and use your personal data (Communication Data and Marketing Data).
We rely on legitimate interest as the lawful basis on which we collect and use your website browsing information (Technical Data).
6. Sensitive data
Sensitive Data includes data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data, criminal convictions and offences. We do not collect any sensitive data.
7. What other organisations process my data?
In order to provide a high quality service, Six String Fingerpicking uses trusted organisations to collect and process your data. These are:
Zenler - Zenler hosted the Six String Fingerpicking Guitar School. To enable you to sign up to the School and access the courses, Zenler collected personal data and was a data processor. For services provided for the School they were also a data controller.
On 21st March 2020 the original School shut down and all course-related data will be handled by Zenler through the Academy only.
Six String Fingerpicking discontinued the use of Zapier 15th December 2019 and instead Mailchimp is directly integrated with the Six String Fingerpicking Academy.
You have the right to opt-out of Analytics cookies by using a browser add-on. This is available here: https://tools.google.com/dlpage/gaoptout
8. Providing your personal data to others
We may 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
9. How long will we hold your personal data?
We will hold your data until you withdraw consent, which you are able to do at any time by contacting email@example.com or using the 'Unsubscribe' link on email communications or by deleting (or requesting deletion of) any public comments made on www.sixstringfingerpicking.com.
When you unsubscribe, your personal data will be deleted within 30 calendar days of your unsubscription/request for deletion.
10. What are your rights under GDPR as a Data Subject?
You are a Data Subject because you are the person whose personal data is being processed and you have the right to:
- request a copy of your personal data which Six String Fingerpicking holds about you
- be informed how your data is being processed and why it is being processed
- request that Six String Fingerpicking corrects any personal data if it is found to be inaccurate or out of date
- request your personal data is erased where it is no longer necessary for Six String Fingerpicking to retain such data
- withdraw your consent to the processing at any time
- request that Six String Fingerpicking transmits your personal data directly to another data controller
- request a restriction be placed on further processing where there is a dispute in relation to the accuracy or processing of your personal data
- object to the processing of personal data
- not be subject to a decision made solely on automated processing
- lodge a complaint with the Information Commissioner’s Office if you are unhappy about how we have handled your personal data
11. Requesting access to your personal information
Under the data protection legislation you have a right of access to information about you that we hold. If you would like to make a request for access to your personal information contact: firstname.lastname@example.org
12. Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner.
If there is 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.
13. Amendments to this Privacy Notice
From time to time this Privacy Notice may be updated by publishing a new version to this page. Should there be a significant change, we will notify you by email or notification on the website home page. Otherwise, you should check back occasionally to ensure you remain happy with the content of this Privacy Notice.
14. Third Party Cookies and Privacy Policies
Third party cookies are those that serve content or advertising on the website. These include when a website user takes a specific action, such as liking or following a post on a social media platform. Six String Fingerpicking has no control over cookies set by third parties.
We use Facebook to host our Facebook Business Page. By being a member of Facebook or using their services you are subject to their Data Policy (whether you use the Six String Fingerpicking Facebook page or not). Their Data Policy can be found at: Facebook Data Policy
15. Who to contact
If you have a concern about the way we are collecting or using your personal data, you should raise your concern with us in the first instance or directly to the Information Commissioner’s Office at https://ico.org.uk/concerns/
The name of Six String Fingerpicking's Data Protection Officer is Chris Murrin. Their contact details are email@example.com
You can also use the website contact form.
10th August 2019
Section 6 (now 7) - Zenler updated to reflect launch of new Academy.
Section 6 (now 7) - Zapier added as a third party trusted organisation.
15th December 2019
Section 6 (now 7) - Updated to state that Zapier ceased to be used to integrate the Six String Fingerpicking Academy and Mailchimp on 15th December 2019.
17th December 2019
Section 14 - List of Third Party Cookies updated to reflect social media sharing buttons.
4th April 2020
Section 3, section 7 and section 14 - Updated to include the use of Google Analytics, which commenced on 25th March 2020.
Zenler - Section updated to reflect the 'School' has been shut down as of 21st March 2020.