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This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.

In the context of the law and this notice, ‘personal data’ is information that clearly identifies you as an individual or which could be used to identify you if combined with other information. Acting in any way on personal data is referred to as ‘processing’.

This notice applies to personal data collected through social media platforms and face to face. (e.g. Facebook, Instagram and Zoom).

Except as set out below, we do not share, or sell, or disclose to a third party, any information.

Personal data we process

1. How we obtain personal data

The information we process about you includes information:

• • you have directly provided to me

  • as a result of monitoring how you use my services

1. Types of personal data we collect directly

When you use my services or buy from me, I ask you to provide personal data. This can be categorised into the following groups:

• • personal identifiers, such as your first and last names, your title and your date of birth

  • contact information, such as your email address, your telephone number and your postal addresses for billing, delivery and communication

  • payment information, such as a debit or credit card number and expiry date and bank account details

  • records of communication between us including messages sent email messages and telephone conversations types of personal data I collect from third parties

We confirm some of the information you provide to us directly using data from other sources. We also add to the information we hold about you, sometimes to remove the need for you to provide it to me and sometimes in order to be able to assess the quality of the services you offer.

The additional information we collect can be categorised as follows:

• • information that confirms your identity

  • business information, including your business trading name and address, your company number (if incorporated), and your VAT number (if registered)

  • information that confirms your contact information

  • unsolicited complaints by other users

1. Types of personal data we collect from your use of my services

By using my services, we process:

• • transaction information that includes the details of the products services you have bought from us and payments made to us for those services

  • your preferences to receive marketing from us; how you wish to communicate with us; and responses and actions in relation to your use of our services.

1. Our use of aggregated information

we may aggregate anonymous information such as statistical or demographic data for any purpose. Anonymous information is that which does not identify you as an individual. Aggregated information may be derived from your personal data but is not considered as such in law because it does not reveal your identity.

However, if we combine or connect aggregated information with your personal data so that it can identify you in any way, we treat the combined information as personal data, and it will be used in accordance with this privacy notice.

1. Special personal data

Special personal data is 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.

We do not collect any special personal data about you.

1. If you do not provide personal data we need

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform that contract.

In that case, we may have to stop providing a service to you. If so, we will notify you of this at the time.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal data, and to notify you of the basis for each category.

If a basis on which we process your personal data is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

1. Information we process because we have a contractual obligation with you

When you buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the information you give. Some of this information may be personal data.

We may use it in order to:

• • verify your identity for security purposes when you use my services

  • sell products to you

  • provide you with my services

  • provide you with suggestions and advice on products, services and how to obtain the most from using my service

We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

1. Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you ask us to provide you more information about my business, including our services, you provide your consent to me to process information that may be personal data.

Wherever possible, we aim to obtain your explicit consent to process this information.

If you have given me explicit permission to do so, I may from time to time pass your name and contact information to selected associates whom we consider may provide services or products you would find useful.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by instructing us info@sandune.online. However, if you do so, you may not be able to use my services further.

We aim to obtain and keep your consent to process your information. However, while we take your consent into account in decisions about whether or not to process your personal data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your personal data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.

1. Information we process for the purposes of legitimate interests

we may process information on the basis there is a legitimate interest, either to you or to us, of doing so.

Where we process your information on this basis, we do after having given careful consideration to:

• • whether the same objective could be achieved through other means

  • whether processing (or not processing) might cause you harm

  • whether you would expect me to process your data, and whether you would, in the round, consider it reasonable to do so

For example, we may process your data on this basis for the purposes of:

• • improving my services

  • record-keeping for the proper and necessary administration of Sandune

  • responding to unsolicited communication from you to which we believe you would expect a response

  • preventing fraudulent use of my services

  • exercising my legal rights, including to detect and prevent fraud and to protect my intellectual property

  • insuring against or obtaining professional advice that is required to manage Sandune risk

  • protecting your interests where we believe we have a duty to do so

1. Information we process because we have a legal obligation

Sometimes, we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your personal data.

1. Information we process to protect vital interests

In situations where processing personal information is necessary to protect someone’s life, where consent is unable to be given and where other lawful bases are not appropriate, we may process personal information on the basis of vital interests.

For example, we may inform relevant organisations if we have a safeguarding concern about a vulnerable person.

How and when we process your personal data

1. Your personal data is not shared

we do not share or disclose to a third party, any information collected.

1. Information you provide

Facebook and Instagram allows you to post information with a view to that information being read, copied, downloaded, or used by other people.

For example, when you leave a review or post a message, we reasonably assume that you consent for the message to be seen by others. Your message may contain information that is personal data.

Other examples include:

• tagging an image

  • In posting personal data, it is up to you to satisfy yourself about the privacy level of every person who might use it.
    
    We do not specifically use this information except to allow it to be displayed or shared.

We do store it, and we reserve a right to use it in the future in any way we decide.

Once your information enters the public domain, we have no control over what any individual third party may do with it. We accept no responsibility for their actions at any time.

Provided your request is reasonable and there is no legal basis for me to retain it, then at our discretion we may agree to your request to delete personal data that you have posted. You can make a request by contacting us at info@sandune.online 

1. Payment information

we store information about your debit or credit card or other means of payment when you first provide it to us.

We store this payment information [at your request] in order to make repeat purchasing of goods and services easier next time.

[we also store it to help us prevent fraud.]

We take the following measures to protect your payment information:

We do not keep all your payment information so as:

• • Access to your payment information is restricted to authorised staff only.

  • If we ask you questions about your payment information, We only show [partial detail OR the first four OR the last four digits of the debit or credit card number], so that you can identify the means of payment to which we refer.

1. Information obtained from third parties

Although we do not disclose your personal data to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up from your personal data from third parties whose services we use.

No such information is personally identifiable to you.

1. Disputes between users

In the event of a dispute between you and another user, provided that you consent, we may share your basic personal data, business information and contact information with the other user.

At my discretion, we may share other information to enable the dispute to be resolved through litigation or alternative dispute resolution methods.

Other matters

1. Your rights

The law requires me to tell you about your rights and our obligations to you in regard to the processing and control of your personal data.

We do this now, by requesting that you read the information provided at http://www.knowyourprivacyrights.org

1. Use of my services by children

we do not sell products or provide services for purchase by children, nor do we market to children.

1. Delivery of services using third party communication software

With your consent, we may communicate using software provided by a third party such as Facebook (WhatsApp), Apple (Facetime), Microsoft (Skype) or Zoom Video Communications (Zoom).

Such methods of communication should secure your personal data using encryption and other technologies. The providers of such software should comply with all applicable privacy laws, rules, and regulations, including the GDPR.

If you have any concerns about using a particular software for communication, please tell us.

1. Control over your own information

It is important that the personal data we hold about you is accurate and up to date. Please inform me if your personal data changes.

At any time, you may contact us to request that we provide you with the personal data we hold about you.

At any time you may review or update personally identifiable information that I hold about you.

To obtain a copy of any information you should contact me to make that request.

When we receive any request to access, edit or delete personal data we first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Please be aware that we are not obliged by law to provide you with all personal data we hold about you, and that if we do provide you with information, the law allows us to charge for such provision if doing so incurs costs for us. After receiving your request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

If you wish us to remove personally identifiable information from my records, you should contact us to make your request.

This may limit the service we can provide to you.

We remind you that we are not obliged by law to delete your personal data or to stop processing it simply because you do not consent to us doing so. While having your consent is an important consideration as to whether to process it, if there is another legitimate basis on which we may process it, we may do so on that basis.

1. Communicating with us

When you contact us, whether by telephone, by email, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of Sandune.

We do not keep any personally identifiable information associated with your message, such as your name or email address.

OR

we may keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

1. Complaining

If you are not happy with my privacy policy, or if you have any complaint, then you should tell me.

When we receive a complaint, we record the information you have given to uson the basis of consent.  We use that information to resolve your complaint.

We aim to investigate all complaints relating to user generated content. However, we may not be able to do so as soon as a complaint is made. If we feel that it is justified or if we believe that the law requires me to do so, we shall remove the content while doing so.

Making a complaint may not result in the removal of the content. Ultimately, we have to make a judgment as to whose right will be obstructed: yours, or that of the person who posted the content that offends you.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

If your complaint reasonably requires us to notify some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion whether we do give information, and if we do, what that information is.

We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal data, you have a right to lodge a complaint with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/.  I would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.

1. Retention period

Except as otherwise mentioned in this privacy notice, we keep your personal data only for as long as required by us:

• • to provide you with the services you have requested

  • to comply with other law, including for the period demanded by our tax authorities

  • to support a claim or defence in court

1. Compliance with the law

Our privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).

1. Review of this privacy policy

We shall update this privacy notice from time to time as necessary.